Memorandum in Support of Motion for Attorney Fees

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION

IN RE: INTERIOR MOLDED DOORS Lead Case 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

MEMORANDUM IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES Case 3:18-cv-00850-JAG Document 349 Filed 05/03/21 Page 2 of 28 PageID# 11160

TABLE OF CONTENTS TABLE OF AUTHORITIES ...... i I. ARGUMENT ...... 3 A. Settlement Class Counsel’s Fee Request is Fair and Reasonable...... 3 1. The Factors for Assessing Percentage-of-Fund Requests Support Settlement Class Counsel’s Fee Request...... 5 a. IPP Class Counsel Obtained an Excellent Result for the Class...... 6 b. The Lack of Objections by Settlement Class Members Supports Settlement Class Counsel’s Fee Request...... 7 c. IPP Class Counsel’s Skill and Efficiency Support Settlement Class Counsel’s Fee Request...... 7 d. The Duration and Complexity of the Litigation Supports the Fee Request...... 9 e. IPP Class Counsel Faced a Significant Risk of Nonpayment...... 10 f. IPP Class Counsel Necessarily Devoted Over 27,800 Hours to Prosecuting this Action...... 12 g. Public Policy Supports the Fee Request...... 12 h. Courts Routinely Grant Fee Awards of 30% or More of the Settlement Fund in Cases Involving Comparable Complexity and Risk...... 13 2. A Cross-Check of IPP Class Counsel’s Lodestar Confirms the Reasonableness of the Fee Request...... 15 B. IPP Class Counsel’s Litigation Costs are Reasonable and Compensable...... 18 C. The Requested Service Awards are Reasonable and Appropriate...... 19 II. CONCLUSION ...... 21

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TABLE OF AUTHORITIES

Page(s)

Cases

Am. Soc’y of Mech. Eng’rs v. Hydrolevel Corp., 456 U.S. 556 (1982) ...... 13

In re Automotive Refinishing Paint Antitrust Litig., MDL No. 1426, 2008 WL 63269 (E.D. Pa. Jan. 3, 2008) ...... 11

Berry v. LexisNexis Risk & Info. Analytics Grp., No. 3:11–CV–754, 2014 WL 4403524 (E.D. Va. Sept. 5, 2014) ...... 20

In re Blech Sec. Litig., No. 94 Civ. 7696, 2002 U.S. Dist. LEXIS 23170 (S.D.N.Y. Nov. 27, 2002) ...... 18

Boeing Co. v. Van Gemert, 444 U.S. 472 (1980) ...... 3

Brown v. Transurban USA, Inc., 318 F.R.D. 560 (E.D. Va. 2016) ...... passim

Burke v. Shapiro, Brown & Alt, LLP, No. 3:14CV201 (DJN), 2016 WL 2894914 (E.D. Va. May 17, 2016) ...... 20

Carroll v. Stettler, No. 10-2262, 2011 WL 5008361 (E.D. Pa. Oct. 19, 2011) ...... 18

Castro v. Sanofi Pasteur Inc., No. 11-cv-7178, 2017 WL 4776626 (D.N.J. Oct. 20, 2017) ...... 6, 10, 17

In re Cathode Ray Tube (CRT) Antitrust Litig., MDL No. 1917, 2013 WL 5429718 (N.D. Cal. June 20, 2013) ...... 9

In re Credit Default Swaps Antitrust Litig., No. 13-md-2476, 2016 WL 2731524 (S.D.N.Y. Apr. 26, 2016) ...... 13

Deem v. Ames True Temper, Inc., No. 6:10-CV-01339, 2013 WL 2285972 (S.D.W. Va. May 23, 2013)...... 6, 14, 20

Faile v. Lancaster Cty., No. 10-cv-2809, 2012 U.S. Dist. LEXIS 189610 (D.S.C. Mar. 8, 2012) ...... 19

In re Flonase Antitrust Litig., 951 F. Supp. 2d 739 (E.D. Pa. 2013) ...... 10

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Galloway v. Williams, No. 3:19-cv-0470, 2020 WL 7482191 (E.D. Va. Dec. 18, 2020) ...... 11

In re Genworth Fin. Secs. Litig., 210 F. Supp. 3d 837 (E.D. Va. 2016) ...... passim

Hooker v. Sirius XM Radio, Inc., No. 13-cv-003, 2017 WL 4484258 (E.D. Va. May 11, 2017) ...... 5, 12

In re Iowa Ready-Mix Concrete Antitrust Litig., No. 10-cv-4038, 2011 WL 5547159 (N.D. Iowa Nov. 9, 2011) ...... 14

Kirven v. Cent. States Health & Life Co., No. 11-cv-2149, 2015 WL 1314086 (D.S.C. Mar. 23, 2015) ...... 8, 14, 15, 20

In re Linerboard Antitrust Litig., 292 F. Supp. 2d 631 (E.D. Pa. 2003) ...... 9

In re Linerboard Antitrust Litig., No. CIV.A. 98-5055, 2004 WL 1221350 (E.D. Pa. June 2, 2004) ...... 8, 13

Manuel v. Wells Fargo Bank, N.A., No. 14-cv-238, 2016 WL 1070819 (E.D. Va. Mar. 15, 2016) ...... 4

Minnesota Mining & Mfg. Co. v. New Jersey Wood Finishing Co., 381 U.S. 311 (1965) ...... 13

Muhammad v. Nat’l City Mortg., Inc., No. 2:07-cv-0423, 2008 WL 5377783 (S.D.W. Va. Dec. 19, 2008) ...... 19

Mylan Pharm., Inc. v. Warner Chilcott Pub. Ltd. Co., No. CV 12-3824, 2014 WL 12778314 (E.D. Pa. Sept. 15, 2014) ...... 15

In re Neustar, Inc. Sec. Litig., No. 1:14CV885, 2015 WL 8484438 (E.D. Va. Dec. 8, 2015) ...... 17

Phillips v. Triad Guar. Inc., No. 1:09-cv-0071, 2016 WL 2636289 (M.D.N.C. May 9, 2016) ...... 11

In re Polyester Staple Antitrust Litig., No. 3:03-cv-1516, ECF No. 45 (W.D.N.C. June 24, 2008) ...... 14, 20

In re Prandin Direct Purchaser Antitrust Litig., 2015 WL 1396473 (E.D. Mich. 2015) ...... 9, 14

In re Remeron Direct Purchaser Antitrust Litig., No. CIV.03-0085 FSH, 2005 WL 3008808 (D.N.J. Nov. 9, 2005) ...... 14

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Seaman v. Duke Univ., No. 1:15-CV-462, 2019 WL 4674758 (M.D.N.C. Sept. 25, 2019) ...... passim

Sims v. BB&T Corp., No. 1:15-cv-0732, 2019 WL 1993519 (M.D.N.C. May 6, 2019) ...... 17, 20

Singleton v. Domino’s Pizza, LLC, 976 F. Supp. 2d 665 (D. Md. 2013) ...... 5, 18, 19

In re Southeastern Milk Antitrust Litig., No. 2:07-CV 208, 2013 WL 2155387 (E.D. Tenn. May 17, 2013) ...... 13

In re Star Scientific, Inc. Secs. Litig., No. 3:13-cv-0183, 2015 WL 13821326 (E.D. Va. June 26, 2015) ...... 14

Strang v. JHM Mortg. Sec. Ltd. P’ship., 890 F. Supp. 499 (E.D. Va. 1995) ...... 4

Temp. Servs., Inc. v. Am. Int’l Grp., Inc., No. 08-cv-271, 2012 WL 13008138 (D.S.C. July 31, 2012) ...... 5, 9

In re TFT-LCD (Flat Panel) Antitrust Litig., No. 07-md-1827, 2013 WL 1365900 (N.D. Cal. Apr. 3, 2013) ...... 9

Thomas v. FTS USA, LLC, No. 13-cv-825, 2017 WL 1148283 (E.D. Va. Jan. 9, 2017) ...... 4, 5, 14, 15

In re Titanium Dioxide Antitrust Litig., No. 10-cv-0318, 2013 WL 6577029 (D. Md. Dec. 13, 2013) ...... 14, 20

Wal-Mart Stores, Inc. v. Visa U.S.A. Inc., 396 F.3d 96 (2d Cir. 2005)...... 13

Yedlowski v. Roka Bioscience, Inc., No. 14-cv-8020, 2016 WL 6661336 (D.N.J. Nov. 10, 2016) ...... 7, 11

Rules

Fed. R. Civ. P. 23(h) ...... 1, 3

Fed. R. Civ. P. 54(d)(2)...... 1

Other Authorities

Natalie Rodriguez, Meet the $2,000 An Hour Attorney: What it Takes to Earn Top Dollar in the Rate-Crunch Era, LAW360 (June 11, 2016) ...... 16

Sara Randazzo & Jacqueline Palank, Legal Fees Cross New Mark: $1,500 an Hour, WALL ST. J. (Feb. 16, 2016) ...... 16

iii

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Pursuant to Federal Rules of Civil Procedure 23(h) and 54(d)(2), Settlement Class

Counsel1 respectfully request: (1) an award of attorneys’ fees in the amount of $5,850,000,

which is equal to 30% of the Settlement Fund, plus interest; (2) reimbursement of expenses and

costs incurred, totaling $3,511,815.63; and (3) service awards of $1,000 each to the 28 class

representatives, to be paid from the Settlement Fund.

Over the course of this litigation, Settlement Class Counsel and the firms working under

their direction (“IPP Class Counsel”) devoted significant effort and millions of dollars of

unreimbursed out-of-pocket expenses to pursue claims on behalf of a class of consumers and

businesses that indirectly purchased Interior Molded Doors not for resale (“Indirect Purchaser

Plaintiffs” or “IPPs”). This work included:

• Performing extensive research into the Interior Molded Door (“IMD”) and Doorskin industries, as well as the federal antitrust laws and the antitrust, consumer protection, and unjust enrichment laws of 32 states and the District of Columbia;

• Engaging in a thorough and extensive pre-filing factual investigation without the benefit of any prior government investigation that culminated in the filing of the Consolidated Class Action Complaint (ECF No. 56) on February 1, 2019, and the Amended Consolidated Class Action Complaint (ECF No. 134) on November 25, 2019;

• Successfully opposing two motions to dismiss filed by Defendants through extensive briefing and oral argument before the Court;

• Spearheading the drafting and negotiation of discovery plans, protocols, a stipulated protective order and numerous stipulations with Defendants;

• Drafting and coordinating discovery against Defendants in conjunction with Direct Purchaser Plaintiffs (“DPPs”), followed by extensive meet and confers with each Defendant;

• Serving deposition and document subpoenas, participating in meet-and-confers, and obtaining discovery from dozens of non-parties, including independent door manufacturers, trade associations, telephone companies and direct purchasers of IMDs;

1 Unless otherwise set forth herein, all defined terms shall have the same meaning as set forth in the Settlement Agreement executed on September 4, 2020. (ECF No. 226-1).

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• Reviewing and analyzing nearly two million pages of documents produced by Defendants and non-parties;

• Developing a database to analyze voluminous telephone records;

• Obtaining, analyzing and producing thousands of pages of documents and data from nearly 30 class representatives, and responding to multiple rounds of detailed Interrogatories and Requests for Production propounded by Defendants;

• Preparing for and defending 29 class representative depositions;2

• Preparing for, taking, and/or participating in the depositions of 15 Defendant witnesses and three non-party witnesses;

• Consulting with IPPs’ expert economist to analyze Defendants’ transactional data and other information produced in discovery and through publicly available sources to develop opinions relating to antitrust impact and damages for purposes of class certification, summary judgment, and trial;

• Working extensively with IPPs’ expert economist in crafting the opening expert report and rebuttal expert report in response to three separate reports filed by Defendants’ three expert economists;

• Working at length with a survey expert to respond to a fourth expert report served by Defendants;

• Preparing for and defending three depositions of IPPs’ experts;

• Preparing for and taking the depositions of four of Defendants’ experts;

• Engaging in substantial motion practice, including successfully opposing Masonite’s motion to transfer venue, successfully opposing two of Defendants’ motions to dismiss IPPs’ complaints, briefing a successful discovery motion, and fully briefing and preparing to argue IPPs’ motion for class certification;

• Performing numerous tasks necessary to achieve the Settlement, including: analyzing economic evidence and data and formulating settlement demands; engaging in extensive arm’s-length negotiations with Defendants; negotiating and preparing drafts of the Settlement Agreement; and preparing the preliminary approval motion and escrow agreement for the Settlement; and

• Crafting, in consultation with IPPs’ class-notice and claims administration expert, an extensive notice program and claims administration process that was approved by the

2 Each of the 28 class representatives named in the Settlement Agreement was deposed. (ECF No. 226-1). In addition, Defendants deposed former class representative Caryn Yost. Ms. Yost’s claims were voluntarily dismissed on January 7, 2020. (ECF No. 148).

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Court, Joint Declaration of William V. Reiss, Daniel C. Hedlund, and Steven N. Williams (“Joint Decl.”) ¶ 4.

The success of these efforts is evident in the outstanding Settlement negotiated by

Settlement Class Counsel, resulting in a $19.5 million payment from Defendants in which, as

indicated in Indirect Purchaser Plaintiffs’ Motion for Final Approval of Settlement, Settlement

Class Counsel intend that each claimant will receive a minimum of $25.00. The Settlement is only possible because of the dedication, effort, and skill of IPP Class Counsel, including their substantial multi-year investment of time and expenses. The request for 30% of the Settlement

Amount plus interest is supported by Fourth Circuit authority. IPP Class Counsel have undertaken a significant risk, invested substantial amounts of their time and money on a contingent basis, and foregone other work opportunities to dedicate their professional efforts to this case. While the work is far from over, with the Fairness Hearing scheduled for July 13, 2021 and months more of overseeing the Settlement administration process ahead, the record fully supports Settlement Class Counsel’s motion.

I. ARGUMENT

A. Settlement Class Counsel’s Fee Request is Fair and Reasonable.

“In a certified class action, the court may award reasonable attorney’s fees and nontaxable costs that are authorized by law or by the parties’ agreement.” Fed. R. Civ. P. 23(h).

The common fund doctrine is based on the federal courts’ power to “prevent . . . inequity by assessing attorney’s fees against the entire fund, thus spreading fees proportionately among those benefited by the suit.” Boeing Co. v. Van Gemert, 444 U.S. 472, 478 (1980). Indeed, the U.S.

Supreme Court “has recognized consistently that . . . a lawyer who recovers a common fund for the benefit of persons other than himself or his client is entitled to a reasonable attorney’s fee from the fund as a whole.” Id.

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Courts use either the percentage-of-the fund method or the lodestar method to calculate

attorneys’ fees in class actions. Brown v. Transurban USA, Inc., 318 F.R.D. 560, 575 (E.D. Va.

2016). For the percentage-of-the-fund method, courts award a percentage of the class’s recovery

to counsel based on several factors. Id. The lodestar method requires multiplying the number of

hours worked by a reasonable hourly rate, the product of which the Court may adjust by utilizing

a “multiplier.” In re Genworth Fin. Secs. Litig., 210 F. Supp. 3d 837, 843 (E.D. Va. 2016)

(Gibney, J.).

Consistent with the majority of courts within the Fourth Circuit, Settlement Class

Counsel base their request on the percentage-of-the–fund method. See Manuel v. Wells Fargo

Bank, N.A., No. 14-cv-238, 2016 WL 1070819, at *5 (E.D. Va. Mar. 15, 2016) (recognizing that

“District Courts within [the Fourth] Circuit have . . . favored the percentage method” and noting the method’s widespread acceptance); Strang v. JHM Mortg. Sec. Ltd. P’ship., 890 F. Supp. 499,

502 (E.D. Va. 1995) (“Although the Fourth Circuit has not yet ruled on this issue, the current trend among the courts of appeal favors the use of a percentage method to calculate an award of attorneys’ fees in common fund cases.”).

The percentage-of-the-fund method is “more efficient and less burdensome than the traditional lodestar method, and offers a more reasonable measure of compensation for common fund cases.” Strang, 890 F. Supp. at 503. It also better aligns the interests of class counsel with the class because it ties attorney’s fees to the result achieved, rather than hours expended by the attorneys. Thomas v. FTS USA, LLC, No. 13-cv-825, 2017 WL 1148283, at *3 (E.D. Va. Jan. 9,

2017), report and recommendation adopted, 2017 WL 1147460 (E.D. Va. Mar. 27, 2017).

The reasonableness of Settlement Class Counsel’s fee request can be confirmed by cross- checking the requested amount against the calculated lodestar. While the percentage of the fund

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method is preferred, “[s]ome courts incorporate the lodestar analysis into the percentage method

by cross-checking the lodestar calculation against the percentage calculation.” Thomas, 2017 WL

1148283, at *4. This “adds an extra layer of assurance as to reasonableness by ensuring that the

fee award is still roughly aligned with the amount of work the attorneys contributed.” Id.

(internal quotation marks omitted). By requesting fees according to a percentage-of-the-fund

calculation and applying a lodestar crosscheck, Settlement Class Counsel’s fee request is in line

with the methodology routinely applied by Courts within the Fourth Circuit.

1. The Factors for Assessing Percentage-of-Fund Requests Support Settlement Class Counsel’s Fee Request.

“The determination of a reasonable fee is within the Court’s discretion guided by the

particular facts and circumstances of the litigation at issue in light of various relevant factors

universally considered by courts in adjudicating common fund fee awards.” Temp. Servs., Inc. v.

Am. Int’l Grp., Inc., No. 08-cv-271, 2012 WL 13008138, at *7 (D.S.C. July 31, 2012). Though

the Fourth Circuit has not yet identified factors for district courts to apply when using the

percentage-of-recovery method, see Singleton v. Domino’s Pizza, LLC, 976 F. Supp. 2d 665, 682

(D. Md. 2013), numerous courts within the Fourth Circuit “look at the following factors: (1) the

result obtained for the class; (2) the presence or absence of substantial objections by members of

the class to the fees requested by counsel; (3) the skill and efficiency of the attorneys involved;

(4) the complexity and duration of the litigation; (5) the risk of nonpayment; (6) the amount of

time devoted to the case by the plaintiffs’ counsel; and (7) awards in similar cases.” In re

Genworth Fin. Secs. Litig., 210 F. Supp. 3d at 843. Some district courts apply a slightly different

version of this standard, replacing the sixth factor with public policy considerations. Hooker v.

Sirius XM Radio, Inc., No. 13-cv-003, 2017 WL 4484258, at *6 (E.D. Va. May 11, 2017). Each

of these factors supports Settlement Class Counsel’s fee request here.

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a. IPP Class Counsel Obtained an Excellent Result for the Class.

“The percentage method is designed to allow courts to award fees from the fund in a

manner that rewards counsel for success and penalizes it for failure.” Deem v. Ames True

Temper, Inc., No. 6:10-CV-01339, 2013 WL 2285972, at *5 (S.D.W. Va. May 23, 2013)

(internal quotation marks omitted); see also Brown, 318 F.R.D. at 577 (“The result achieved is

among the most important factors to be considered in making a fee award.”). IPP Class Counsel

secured a $19.5 million Settlement, which, after deducting attorneys’ fees, service awards, and

costs and expenses associated with this litigation and the Settlement administration, will be

distributed to the Settlement Class years earlier than it would be if litigation against Defendants

continued and IPPs were successful through trial and appeal. As indicated in the Indirect

Purchaser Plaintiffs’ Motion for Final Approval of Settlement with Defendants, filed

contemporaneously with this motion, Settlement Class Counsel anticipates that each Settlement

Class Member that submits a valid claim form will receive a minimum of $25, regardless of how

many IMDs they purchased. This represents a significant cash recovery for the Settlement Class,

which may not have been available in light of the legal burdens imposed on IPPs and the

numerous and vigorous defenses asserted by Defendants. See Seaman v. Duke Univ., No. 1:15-

CV-462, 2019 WL 4674758, at *4 (M.D.N.C. Sept. 25, 2019) (noting that antitrust class counsel

“ha[ve] a number of hurdles to overcome”).

Moreover, such compensation would not have been available to class members without

the dedication and efforts of IPP Class Counsel. Notably, there was no government investigation

or other independent body seeking restitution for IPPs or seeking to uncover the unlawful

conduct alleged here. See Castro v. Sanofi Pasteur Inc., No. 11-cv-7178, 2017 WL 4776626, at

*9 (D.N.J. Oct. 20, 2017) (fact that the “case was investigated and brought entirely by private

counsel” was a benefit attributable to class counsel and factor weighing “strongly” in favor of 6

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court approval of the requested 33-1/3% fee award); In re Genworth Fin. Secs. Litig., 210 F.

Supp. 3d at 845 (“Looking at the complexity of the litigation and the fact that the plaintiffs did

not bring this case as a tag-along suit to a government investigation, the substantial attorneys’

fees award in this case is justified . . . .”). Balanced against the many significant risks, discussed

infra, the Settlement value here provides an excellent result for the Settlement Class and supports

Settlement Class Counsel’s request for attorneys’ fees.

b. The Lack of Objections by Settlement Class Members Supports Settlement Class Counsel’s Fee Request.

“A lack of objections by class members as to fees requested by counsel weighs in favor

of the reasonableness of the fees.” In re Genworth Fin. Secs. Litig., 210 F. Supp. 3d at 844.

Significantly, not a single Settlement Class Member has yet opted out of or objected to the

settlement. However, the deadline for objections is June 2, 2021, and Settlement Class Counsel

will advise the Court as to this factor at or prior to the July 13, 2021 Fairness Hearing.

c. IPP Class Counsel’s Skill and Efficiency Support Settlement Class Counsel’s Fee Request.

The quality of the representation is another significant factor supporting Settlement Class

Counsel’s fee request. See In re Genworth Fin. Secs. Litig., 210 F. Supp. 3d at 844 (“The skill

required in complex cases such as this involving massive discovery efforts and complicated

issues of fact and law also weighs in favor of supporting the substantial attorneys’ fees award in

this case.”). Settlement Class Counsel are all highly experienced and highly skilled specialists in

antitrust and class action litigation, as can be seen in the firm resumes accompanying their

declarations. See Joint Decl., Ex. A. Furthermore, Settlement Class Counsel believe that the

quality and skill of the work undertaken to aggressively litigate this case is amply demonstrated

by the quality of the work product proffered in this case, as well as by the results achieved

because of that work. See Yedlowski v. Roka Bioscience, Inc., No. 14-cv-8020, 2016 WL

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6661336, at *20 (D.N.J. Nov. 10, 2016) (“Lead Counsel’s skill and efficiency is ‘measured by

the quality of the result achieved, the difficulties faced, the speed and efficiency of the recovery,

the standing, experience and expertise of the counsel, the skill and professionalism with which

counsel prosecuted the case and the performance and quality of opposing counsel.’”). Judge

Gibney himself has recognized Settlement Class Counsel’s capabilities, noting they “obviously,

are very skilled in this kind of matter.” See Prelim. Approval Hearing Transcr. (Feb. 5, 2021), at

Further, IPP Class Counsel’s work resulted in a substantial benefit to the class: a $19.5

million Settlement. See In re Linerboard Antitrust Litig., No. CIV.A. 98-5055, 2004 WL

1221350, at *5 (E.D. Pa. June 2, 2004), amended, 2004 WL 1240775 (E.D. Pa. June 4, 2004)

(“[T]he result achieved is the clearest reflection of petitioners’ skill and expertise.”). IPP Class

Counsel achieved this result despite the vigorous opposition of Defendants, who were

represented by highly sophisticated and capable attorneys at McGuireWoods LLP, Kirkland &

Ellis LLP, Williams Mullen, and Eimer Stahl LLP.3 See Kirven v. Cent. States Health & Life

Co., No. 11-cv-2149, 2015 WL 1314086, at *13 (D.S.C. Mar. 23, 2015) (in considering the

quality and skill of the attorneys involved factor, stating that “the court is in complete agreement

with class counsel’s observation that the result obtained was uncertain and particularly difficult

to obtain given the experience and skill of opposing counsel”) (internal quotation marks

3 Defendant Masonite was represented by Eimer Stahl, whose “Antitrust attorneys have decades of experience in litigating high-stakes civil and criminal antitrust matters” and have received numerous accolades “as a national leader in Antitrust Law.” See https://www.eimerstahl.com /practices-Antitrust. Jeld-Wen was represented by Kirkland & Ellis, a global firm with over 700 lawyers that has been labeled as one of “The Most-feared Firms in Litigation” and “Ranked #1 in the Global Litigation Top 50” by The Lawyer magazine. See https://www.kirkland.com/services /practices/litigation. Defendants were also represented locally by highly skilled and experienced attorneys at Williams Mullen and McGuireWoods.

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omitted); Temp. Servs. Inc., 2012 WL 13008138, at *26 (“Here, the Defendants were vigorously

represented by a team of experienced, capable, and relentless counsel from highly reputable law

firms. These facts support approval of the requested attorneys’ fee award.”). That IPP Class

Counsel achieved this result in the face of such vigorous opposition further supports the fee

request.

d. The Duration and Complexity of the Litigation Supports the Fee Request.

The complexity and duration of this litigation supports Settlement Class Counsel’s fee

request. Antitrust class actions are “arguably the most complex action[s] to prosecute. . . . The

legal and factual issues involved are always numerous and uncertain in outcome.” In re

Linerboard Antitrust Litig., 292 F. Supp. 2d 631, 639 (E.D. Pa. 2003); see also In re Prandin

Direct Purchaser Antitrust Litig., 2015 WL 1396473, at *5 (E.D. Mich. 2015) (“Antitrust class

actions are inherently complex.”). This indirect purchaser action was particularly complex.

In addition to the challenges inherent to antitrust class actions, IPPs faced substantial

additional difficulties as indirect purchasers. As indirect purchasers, IPPs’ claims for damages

and restitution are based on both federal law and the laws of twenty-one states. This creates

substantial additional risk, uncertainty, and complexity. As one court noted in an indirect

purchaser action involving allegations of price-fixing of component parts by defendants,

“[a]ssessment of damages involved a difficult analysis, which required taking into account the

impact of and relationship between federal and state rules concerning damage analysis . . . .” In

re TFT-LCD (Flat Panel) Antitrust Litig., No. 07-md-1827, 2013 WL 1365900, at *7 (N.D. Cal.

Apr. 3, 2013). In addition to the difficulties associated in bringing claims under various state

laws, IPPs also “have the burden of demonstrating that there is a reasonable method for

determining on a class-wide basis whether and to what extent that overcharge was passed on to

each of the indirect purchasers at all levels of the distribution chain.” In re Cathode Ray Tube 9

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(CRT) Antitrust Litig., MDL No. 1917, 2013 WL 5429718, at *12 (N.D. Cal. June 20, 2013).

Such hurdles make indirect purchaser antitrust class actions particularly challenging.

IPP Class Counsel achieved this Settlement after nearly two years of hard-fought

litigation, notwithstanding the additional challenges posed by the COVID-19 global pandemic.

Since this case was filed on December 11, 2018, IPP Class Counsel: (i) successfully defeated the

lion’s share of Defendants’ two motions to dismiss; (ii) completed expert and fact discovery,

involving the production of nearly two million pages of documents and the taking and defending

of dozens of depositions under an aggressive discovery schedule; (iii) fully briefed class

certification and prepared to argue the motion; and (iv) engaged in a series of vigorous and

protracted arms-length settlement negotiations with Defendants. Joint Decl. ¶ 4.

The factual and legal development of this case was accomplished without the benefit of a

parallel government investigation or litigation. Joint Decl. ¶ 9. The complexity and duration of

this case firmly support the reasonableness of Settlement Class Counsel’s request for 30% of the

Settlement Fund. See, e.g., Castro, 2017 WL 4776626, at *9 (recognizing that “an antitrust class

action is arguably the most complex action to prosecute” and granting one third of the settlement

fund in attorneys’ fees in case that had been litigated for years); Seaman, 2019 WL 4674758, at

*3 (finding that the “complex[ity]” of an antitrust class action with “numerous contested issues”

provided “more than sufficient reason to support a one-third contingent fee”); In re Flonase

Antitrust Litig., 951 F. Supp. 2d 739, 743 (E.D. Pa. 2013) (“Antitrust class actions are

particularly complex to litigate and therefore quite expensive.”).

e. IPP Class Counsel Faced a Significant Risk of Nonpayment.

The determination of a reasonable fee must include consideration of the contingent nature

of IPP Class Counsel’s decision to devote their time and labor to this litigation, the equally

contingent outlay of millions of dollars of out-of-pocket costs and expenses, and the fact that that 10

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the risks of failure in a class action are notoriously high. As a result, “Courts across the country

have consistently recognized that the risk of receiving little or no recovery is a major factor in

considering an award of attorneys’ fees.” Yedlowski, 2016 WL 6661336, at *65; see also

Galloway v. Williams, No. 3:19-cv-0470, 2020 WL 7482191 (E.D. Va. Dec. 18, 2020)

(recognizing that “class counsel operat[ing] on a contingency basis” face “a very real risk of

nonpayment” and that “[t]his factor therefore weights in favor of the reasonableness of the

award”).4

Since 2018, IPP Class Counsel have prosecuted this case on a 100% contingent basis

both as to fees and expenses. Joint Decl. ¶ 10. There was no guarantee they would receive

reimbursement for any of their attorneys’ fees or the millions of dollars of expenses they

necessarily incurred on behalf of the class. And IPP Class Counsel persisted in the litigation even

after the Court dismissed a portion of IPPs’ claims, all the while paying out-of-pocket costs and

4 While taking on any multi-million-dollar indirect purchaser antitrust class action on an entirely contingent basis would be risky, this one was particularly so. To begin, IPP Class Counsel investigated this case from the ground up without the benefit of a government investigation, which significantly increased the risk of bringing this action. See, e.g., In re Automotive Refinishing Paint Antitrust Litig., MDL No. 1426, 2008 WL 63269, at *5 (E.D. Pa. Jan. 3, 2008) (“The risk of nonpayment is even higher when a defendants’ prima facie liability has not been established by the government in a criminal action.”). Furthermore, while Settlement Class Counsel are confident that the proposed litigation class would have been certified, class certification presented a particular challenge for IPPs, with Defendants vigorously contending, inter alia, that: (1) the inclusion of contractors in the proposed class precluded findings of ascertainability, typicality, and adequacy; (2) there is no administratively feasible way to identify class members who purchased Defendant-manufactured IMDs; (3) damages could not be shown with common evidence; (4) IPPs’ damages methodology could not accurately or adequately calculate damages; and (5) state law issues predominated. ECF No. 200. See also Phillips v. Triad Guar. Inc., No. 1:09-cv-0071, 2016 WL 2636289, at *6 (M.D.N.C. May 9, 2016) (finding fee award justified where, “Lead Counsel bore the risks involved with surviving dispositive motions, obtaining class certification, proving liability, causation, and damages, prevailing with experts, and litigating through trial and possible appeals” knowing “that the only way [they] would be compensated was to achieve a successful result”).

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expenses needed to effectively litigate this case. Joint Decl. ¶¶ 4, 22. The requested fee award is

reasonable in light of the substantial risks involved.

f. IPP Class Counsel Necessarily Devoted Over 27,800 Hours to Prosecuting this Action.

IPP Class Counsel devoted significant time and energy, over 27,848 hours to this matter,

resulting in a total lodestar of $13,607,313.00 from the inception of the case on February 8,

20185 through February 28, 2021. IPP Class Counsel could have spent those attorney hours

litigating other cases, which weighs in favor of awarding the requested fees. See, e.g., Seaman,

2019 WL 4674758, at *4 (explaining that the “attorneys and staff have worked over 12,500

hours since it began” and “spent over $3 million from their own pockets litigating this case,”

which “was time and money the attorneys could have directed to other simpler and less risky

opportunities” supported the fee request); In re Genworth Fin. Sec. Litig., 210 F. Supp. 3d at

844-45 (finding that “counsel for plaintiffs devoted an enormous amount of time and effort into

this case, totaling more than 66,000 hours and investing more than three million dollars in fees

towards consulting experts” to be among the considerations that “support the attorneys’ fees

award”). The prodigious time and resources IPP Class Counsel committed to this case weigh in

favor of the requested fee.

g. Public Policy Supports the Fee Request.

“Incentives for counsel to undertake worthy class action lawsuits are important because

class actions serve to provide relief when it would be inefficient for an individual to pursue a

claim.” Hooker, 2017 WL 4484258, at *8. Indeed, “failing to fully compensate class counsel for

the excellent work done and the various substantial risks taken would undermine society’s

5 “Inception” refers to February 8, 2018, the date upon which IPP Class Counsel first began investigating the claims at issue in this litigation. 12

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interest in the private litigation of antitrust cases.” In re Southeastern Milk Antitrust Litig., No.

2:07-CV 208, 2013 WL 2155387, at *5 (E.D. Tenn. May 17, 2013). Such fees are particularly

important in antitrust cases, where “Congress has expressed its belief that private antitrust

litigation is one of the surest weapons for effective enforcement of the antitrust laws.” Minnesota

Mining & Mfg. Co. v. New Jersey Wood Finishing Co., 381 U.S. 311, 318 (1965).

This lawsuit serves the interests of both the public and the private class members.

Granting Settlement Class Counsel’s fee request incentivizes this type of worthy private

litigation, which in turn encourages private actions that aim to uncover fraud and upend unlawful

anticompetitive practices in the marketplace. Am. Soc’y of Mech. Eng’rs v. Hydrolevel Corp.,

456 U.S. 556, 572 n.10 (1982) (“[P]rivate suits are an important element of the Nation’s antitrust

enforcement effort . . . .”); Wal-Mart Stores, Inc. v. Visa U.S.A. Inc., 396 F.3d 96, 122 (2d Cir.

2005) (“[I]t is especially important to provide appropriate incentives to attorneys pursuing

antitrust actions because public policy relies on private sector enforcement of the antitrust

laws.”); In re Credit Default Swaps Antitrust Litig., No. 13-md-2476, 2016 WL 2731524, at *18

(S.D.N.Y. Apr. 26, 2016) (“It is important to encourage top-tier litigators to pursue challenging

antitrust cases . . . [because] [o]ur antitrust laws address issues that go to the heart of our

economy.”); In re Linerboard Antitrust Litig., 2004 WL 1221350, at *17 (“[T]he incentive for

‘the private attorney general’ is particularly important in the area of antitrust enforcement

because public policy relies so heavily on such private action for enforcement of the antitrust

laws.”).

h. Courts Routinely Grant Fee Awards of 30% or More of the Settlement Fund in Cases Involving Comparable Complexity and Risk.

The final factor considers fee awards in similar cases. Settlement Class Counsel’s request

of 30% of the Settlement Amount falls within the range regularly approved in other class actions,

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including those within courts in the Fourth Circuit, including this District. See Brown, 318

F.R.D. at 578 (awarding attorneys’ fees of approximately 48% of the settlement fund, which with

expenses totaled half the $1,350,000 settlement fund); In re Star Scientific, Inc. Secs. Litig., No.

3:13-cv-0183, 2015 WL 13821326 (E.D. Va. June 26, 2015) (Gibney, J.) (awarding attorneys’

fees of one third of $5,900,000 settlement fund); Kirven, 2015 WL 1314086, at *13 (awarding

attorneys’ fees of one third of approximately $510,000 settlement fund); Deem, 2013 WL

2285972, at *7 (awarding attorneys’ fees of one third of $405,000 settlement fund); see also

Seaman, 2019 WL 4674758 (antitrust case; awarding attorneys’ fees of one third of the

settlement fund); In re Titanium Dioxide Antitrust Litig., No. 10-cv-0318, 2013 WL 6577029 (D.

Md. Dec. 13, 2013) (same); In re Polyester Staple Antitrust Litig., No. 3:03-cv-1516, ECF No.

45 (W.D.N.C. June 24, 2008) (same), available at Joint Decl., Ex. C.6

Additionally, “[t]he percentage-of-the-fund method of awarding attorneys’ fees in class

actions should approximate the fee which would be negotiated if the lawyer were offering his or

her services in the private marketplace.” In re Remeron Direct Purchaser Antitrust Litig., No.

CIV.03-0085 FSH, 2005 WL 3008808, at *16 (D.N.J. Nov. 9, 2005). “Attorneys regularly

contract for contingent fees between 30% and 40% with their clients in non-class, commercial

litigation.” Id.; see also Thomas, 2017 WL 1148283, at *5 (“[A]ny discussion of percentage

awards should acknowledge the age-old assumption that a lawyer receives a third of his client’s

recovery under most contingency agreements.”). Given that “a one-third contingency is standard

6 Courts outside the Fourth Circuit presiding over antitrust class actions routinely award settlement class counsel attorneys’ fees in excess of 30% of the settlement fund. See, e.g., In re Prandin Direct Purchaser Antitrust Litig., No. No. 2:10–cv–12141–AC–DAS, 2015 WL 1396473 (E.D. Mich. January 20, 2015) (awarding attorneys’ fees of one-third of $19 million settlement fund); In re Iowa Ready-Mix Concrete Antitrust Litig., No. 10-cv-4038, 2011 WL 5547159 (N.D. Iowa Nov. 9, 2011) (awarding attorneys’ fees of approximately 36% of $18.5 million settlement fund). 14

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in individual litigation; in antitrust litigation, a higher contingency would be reasonable, given

the complexities and risks involved.” Mylan Pharm., Inc. v. Warner Chilcott Pub. Ltd. Co., No.

CV 12-3824, 2014 WL 12778314, at *7 (E.D. Pa. Sept. 15, 2014). Consideration of the awards

in similar cases supports the requested award of 30% of the Settlement Fund here.

2. A Cross-Check of IPP Class Counsel’s Lodestar Confirms the Reasonableness of the Fee Request.

Courts frequently supplement their analysis of the percentage-of-fund method with the

lodestar cross-check. In re Genworth Fin. Secs. Litig., 210 F. Supp. 3d at 843. To apply the

lodestar method, courts “multiply[] the number of hours worked by the plaintiffs’ counsel by a

reasonable hourly rate and compare[] that figure against the attorneys’ fees award to develop a

‘multiplier’ for the amount requested.” Id. “Use of the lodestar calculation as a cross-check to the

percentage method adds an extra layer of assurance as to reasonableness by ensuring that the fee

award is still roughly aligned with the amount of work the attorneys contributed.” Thomas, 2017

WL 1148283, at *4 (internal quotation marks omitted); see also Kirven, 2015 WL 1314086, at

*12 (“Using the percentage method, cross-checked by the lodestar method, reduces the risk that

the amount of the fee award either overcompensates counsel in relation to the class benefits

obtained or undercompensates counsel for their work.”). Because the lodestar cross-check is not

the principal method used to test the reasonableness of a fee request, it does not require the

“exhaustive scrutiny” of time records that might otherwise be required. Thomas, 2017 WL

1148283, at *4.

IPP Class Counsel have vigorously prosecuted this litigation with a keen eye to efficiency

and economy. Joint Decl. ¶¶ 6, 15-17. As shown in each of the firm’s declarations submitted

with this motion, counsel representing IPPs and their professional staff have from inception of

the case through February 28, 2021, worked 27,848.16 hours on this litigation. Id., Ex. A.

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Discovery in this case was extensive and included: producing discovery for the 29 named

plaintiffs;7 (2) conducting massive discovery on Defendants and dozens of third-parties; and (3)

engaging in extensive expert discovery. Id. ¶ 4.8 There has also been extensive motion practice

related to the merits of the case and class certification. Id. Furthermore, Settlement Class

Counsel has ensured that the work done by IPP Class Counsel was performed at the direction of

Settlement Class Counsel and was not duplicative. Id. ¶ 17.

Applying the rates charged by counsel to the hours expended yields a “lodestar” of

$13,607,313.00. Joint Decl. ¶ 11. This lodestar is based on counsel’s historical rates rather than

current rates, even though the use of current rates is “appropriate to account for the delay in

payment to counsel.” Seaman, 2019 WL 4674758, at *5. These rates are reasonable based on

each person’s position, experience level, and location. Joint Decl. ¶¶ 12-14.9

Although a reasonable rate is generally “determined by looking at the local market . . . a

higher rate can be appropriate for matters involving complex issues requiring specialized

expertise,” such as an antitrust class action like this one. Seaman, 2019 WL 4674758, at *5

(citations omitted).10 Indeed, “[g]iven the complexity and risk involved, it is reasonable to use a

7 Each of the 28 class representatives named in the Settlement Agreement was deposed. (ECF No. 226-1). In addition, Defendants deposed former class representative Caryn Yost. Ms. Yost’s claims were voluntarily dismissed on January 7, 2020. (ECF No. 148). 8 Third-party discovery in this case was particularly intensive, involving subpoenas to telephone carriers seeking telephone records of Defendants’ executives, as well as to industry trade associations, independent door manufacturers, private equity firms currently or formerly affiliated with Defendants, and direct purchasers of IMDs. 9 Settlement Class Counsel also capped the hourly billing rate for attorneys conducting first-level document review at $300 per hour. Joint Decl. ¶ 18. 10 See also Sara Randazzo & Jacqueline Palank, Legal Fees Cross New Mark: $1,500 an Hour, WALL ST. J. (Feb. 16, 2016), https://www.wsj.com/articles/legal-fees-reach-new-pinnacle-1-500- an-hour-1454960708 (recognizing that hourly rates for specialties such as “antitrust and high- stakes litigation and appeals . . . hourly rates can hit $1,800 or even $1,950); Natalie Rodriguez, Meet the $2,000 An Hour Attorney: What it Takes to Earn Top Dollar in the Rate-Crunch Era, 16

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non-local hourly rate to calculate a reasonable rate for purposes of the lodestar comparison to the

percentage fee.” See id. (applying a rate in line with antitrust class actions class nationwide

where “antitrust lawyers exist[ed] locally” but there were “not many firms willing to handle a

high-risk matter requiring the resources, time, and skill this case demanded”); Sims v. BB&T

Corp., No. 1:15-cv-0732, 2019 WL 1993519 (M.D.N.C. May 6, 2019) (considering rates up to

$1,060 as part of a lodestar cross-check where “Class Counsel displayed skill and determination”

and it was “unsurprising that only a few firms might invest the considerable resources to . . .

class actions such as this, which require considerable resources and hold uncertain potential for

recovery”).

This lodestar crosscheck demonstrates the reasonableness of the requested fee. The

requested fee represents a negative “multiplier” of the lodestar of approximately .43, a

substantial discount off IPP Class Counsel’s billing rates. Joint Decl. ¶ 11.11 Courts routinely

grant attorneys’ fees of 30% or more of the settlement amount where the lodestar crosscheck

reveals a negative lodestar multiplier. See Brown, 318 F.R.D. at 578 (awarding half of the gross

settlement amount in attorneys’ fees (approximately 48%) and expenses where “Class Counsel’s

LAW360 (June 11, 2016), https://www.law360.com/in-depth/articles/804421 (“[E]arlier this year, BTI Consulting Group found that a handful of in-house counsel had paid as much as $2,000 per hour, after discounts, to attorneys in the past year. Several other in-house counsel, meanwhile, had paid highs of $1,900 per hour or $1,800 per hour.”). Furthermore, IPP Class Counsel’s rates are in line with those of DPP Class Counsel, In re Interior Molded Doors Antitrust Litig., No. 3:18-cv-0718 (E.D. Va.) (ECF No. 363), and it is also highly likely that IPP Class Counsel’s billing rates compare favorably with those of Defendants’ lead counsel, based in Chicago and Washington, DC. 11 Given that the substantial negative multiplier, even if all IPP Class Counsel’s rates were cut in half, the lodestar multiplier would still only be .86, which is still well within the acceptable range. See In re Neustar, Inc. Sec. Litig., No. 1:14CV885 (JCC/TRJ), 2015 WL 8484438, at *10 (E.D. Va. Dec. 8, 2015) (noting that although counsel’s rates were above local market rates, given the low multiplier “the fee request would remain reasonable if the Court were to discount the total lodestar figure by fifty percent”).

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requested fee represents a negative multiplier of 0.77”); see also Castro, 2017 WL 4776626, at

*9; Carroll v. Stettler, No. 10-2262, 2011 WL 5008361, at *8 (E.D. Pa. Oct. 19, 2011)

(recognizing that “[a] lodestar multiplier of less than one reveals that the fee request constitutes

only a fraction of the work that the attorneys billed and is within the accepted range” and

awarding one third of the settlement fund in attorneys’ fees); In re Blech Sec. Litig., No. 94 Civ.

7696, 2002 U.S. Dist. LEXIS 23170, at *5 (S.D.N.Y. Nov. 27, 2002) (awarding one third of the

settlement fund in attorneys’ fees where “[t]he fee requested is less than the cumulative

lodestar”). In fact, courts within the Fourth Circuit regularly grant fee awards that reflect a

significant positive multiplier of counsel’s lodestar. See In re Genworth Fin. Secs. Litig., 210 F.

Supp. at 845 (“District courts within the Fourth Circuit have regularly approved attorneys’ fees

awards with 2-3 times lodestar multipliers.”); Brown, 318 F.R.D. at 578 (observing that “recent

cases in the Eastern District of Virginia shows that courts have awarded fees that included

‘multipliers’ of at or greater than two”); Singleton, LLC, 976 F. Supp. 2d at 689 (“The range of

multipliers on large and complicated class actions have ranged from at least 2.26 to 4.5.”). The

lodestar crosscheck supports the reasonableness of the fee request.

B. IPP Class Counsel’s Litigation Costs are Reasonable and Compensable.

Settlement Class Counsel also request reimbursement of the costs and expenses that IPP

Class Counsel necessarily incurred in this litigation. “It is well-established that plaintiffs who are

entitled to recover attorneys’ fees are also entitled to recover reasonable litigation-related

expenses as part of their overall award.” Singleton, 976 F. Supp. 2d at 689 (internal quotation

marks omitted). IPP Class Counsel have incurred $3,511,815.63 in unreimbursed costs and

expenses in prosecuting this litigation and have documented and detailed these expenses. Joint

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Decl., Exs. A & B.12 These expenses include filing fees, travel, document hosting, expert fees,

deposition video and transcription expenses, and copying costs, among others.13 Id. Notably, of

the $3,511,815.63 incurred in costs and expenses, $3,072,953.68 pertained to expert fees. Joint

Decl., Exs. A-3, A-13, B.

IPP Class Counsel’s costs and expenses are of the sort that would typically be billed to

paying clients in the marketplace. See In re Genworth Fin. Secs. Litig., 210 F. Supp. 3d at 845-46

(approving costs related to experts, travel, court reports, and electronic discovery); Singleton,

976 F. Supp. 2d at 689 (awarding reimbursement for filing fees, travel costs, and copies). The

expenses detailed in the accompanying declarations, Joint Decl., Exs. A & B, were reasonable

and reasonably incurred, and should therefore be reimbursed in full.

C. The Requested Service Awards are Reasonable and Appropriate.

Lastly, Settlement Class Counsel request $1,000 in service awards for each of the 28

class representatives. “It is very common in class action cases for service or incentive payments

to be paid to class representatives in addition to their proportionate share of the recovery.” Faile

v. Lancaster Cty., No. 10-cv-2809, 2012 U.S. Dist. LEXIS 189610, at *41 (D.S.C. Mar. 8, 2012).

Such awards “compensate Plaintiffs for their additional efforts, risks, and hardships they have

undertaken as class representatives on behalf of the group in filing and prosecuting the action.”

12 IPP Class Counsel’s expenses included contributions to a common litigation fund, which was used to pay certain common expenses, including, among other things, expert costs. As is typical in antitrust class actions, the expert costs incurred by IPP Class Counsel comprised a substantial portion of the overall expenses. These common litigation fund expenses are detailed in the Declaration of William V. Reiss Regarding the Litigation Fund in Support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the Class Representatives, attached to the Joint Declaration as Exhibit B. 13 The total amount of the incurred expenses is less than the amount stated in the Notice to potential Settlement Class members, which stated that Settlement Class Counsel would ask permission to “to reimburse Settlement Class Counsel for certain costs and expenses, not to exceed $5 million.” See ECF No. 297-1 at 45.

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Id. at *41; see also Muhammad v. Nat’l City Mortg., Inc., No. 2:07-cv-0423, 2008 WL 5377783,

at *9 (S.D.W. Va. Dec. 19, 2008) (“Class members would have received nothing had [the

plaintiff] not been willing to step up and file this action. [The plaintiff] gave his time and effort

to prosecute the case.”).

Settlement Class Counsel respectfully request that the Court approve $1,000 in service

awards for each of the 28 class representatives in recognition of their essential contributions in

the prosecution of this litigation. Each class representative responded to Defendants’ discovery

requests, including multiple rounds of interrogatories and requests for production. Joint Decl. ¶¶

4, 26. Doing so required them to search their records and locate documents responsive to

Defendants’ requests. Id. Additionally, each class representative was deposed as part of this

litigation. Id. These efforts were integral to the litigation and to achieving a class-wide

settlement. The service awards requested here are in line with other service awards in this

District. See, e.g., Berry v. LexisNexis Risk & Info. Analytics Grp., No. 3:11–CV–754, 2014 WL

4403524, at *16 (E.D. Va. Sept. 5, 2014), aff’d sub nom. Berry v. Schulman, 807 F.3d 600 (4th

Cir. 2015) (approving a $5,000 service award for each named plaintiff); Burke v. Shapiro, Brown

& Alt, LLP, No. 3:14CV201 (DJN), 2016 WL 2894914, at *6 (E.D. Va. May 17, 2016)

(approving a $3,000 service award for each plaintiff); Deem, 2013 WL 2285972, at *6–7

(approving award of $7,500 per lead plaintiff); In re Polyester Staple Antitrust Litig., No. 3:03-

cv-1516, ECF No. 45 (W.D.N.C. June 24, 2008) (awarding $10,000 for each named plaintiff).14

14 The aggregate amount of service awards requested here, $28,000, comprises approximately .14% of the Settlement Fund. Courts routinely award service awards comprising a greater portion of the settlement amount, see Sims v. BB&T Corp., 2019 WL 1993519, at *4-5 (awarding approximately .83% of the settlement fund in service awards); Kirven, 2015 WL 1314086, at *13 (1.48%); Deem, 2013 WL 2285972, at *7 (5.56%); Brown, 318 F.R.D. at 578 (.23% of $1,350,000 settlement), and greater aggregate amounts, see Sims v. BB&T Corp., 2019 WL 20

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II. CONCLUSION

For the reasons set forth above, and as supported in the attached accompanying

declarations submitted herewith, Settlement Class Counsel respectfully request the Court (i)

grant Settlement Class Counsel’s fee request of 30% of the Settlement Fund totaling $5,850,000,

plus interest on that amount; (ii) reimburse reasonable litigation costs and expenses incurred by

IPP Class Counsel of $3,511,815.63; and (iii) grant service awards of $1,000 to each of the 28

class representatives.

Dated: May 3, 2021 Respectfully submitted,

/s/Conrad Shumadine ______Conrad M. Shumadine (VSB #4325) WILLCOX & SAVAGE, P.C. 440 Monticello Avenue, Suite 2200 Norfolk, Virginia 23510 Tel: (757) 628-5500 Fax: (757) 628-5566 Email: [email protected]

Liaison Counsel for the Settlement Class

Daniel E. Gustafson William V. Reiss Daniel C. Hedlund Adam C. Mendel Michelle J. Looby ROBINS KAPLAN LLP Kaitlyn L. Dennis 399 Park Avenue, Suite 3600 GUSTAFSON GLUEK PLLC New York, NY 10022 120 South 6th Street, Suite 2600 Tel: (212) 980-7400 Minneapolis, MN 55402 Fax: (212) 980-7499 Tel: (612) 333-8844 Email: [email protected] Fax: (612) 339-6622 [email protected] Email: [email protected] [email protected] [email protected] [email protected]

1993519, at *4-*5 (awarding $200,000 in service awards); Seaman, 2019 WL 4674758, at *7 ($125,000); In re Titanium Dioxide Antitrust Litig., 2013 WL 6577029, at *1 ($175,000).

Case 3:18-cv-00850-JAG Document 349 Filed 05/03/21 Page 27 of 28 PageID# 11185

Joseph R. Saveri Steven N. Williams Kyle P. Quackenbush THE JOSEPH SAVERI LAW FIRM LLP 601 California Street, Suite 1000 San Francisco, CA 94108 Tel: (415) 500-6800 Fax: (415) 395-9940 Email: [email protected] [email protected] [email protected]

Settlement Class Counsel

Case 3:18-cv-00850-JAG Document 349 Filed 05/03/21 Page 28 of 28 PageID# 11186

CERTIFICATE OF SERVICE

I hereby certify that on the 3rd day of May 2021, a copy of the foregoing

document was filed electronically on the Court’s Electronic Case Filing (ECF) system. A Notice

of Electronic Filing (NEF) will be sent by operation of the Court’s ECF system to the filing

party, the assigned Judge, and any registered user in the case as indicated on the NEF.

To the best of my knowledge, there are no other attorneys or parties who require service

by U.S. Mail.

s/Conrad Shumadine _ Conrad M. Shumadine (VSB #4325) WILLCOX & SAVAGE, P.C. 440 Monticello Avenue, Suite 2200 Norfolk, Virginia 23510 Tel: (757) 628-5500 Fax: (757) 628-5566 Email: [email protected]

Liaison Counsel for the Settlement Class

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

JOINT DECLARATION OF WILLIAM V. REISS, DANIEL C. HEDLUND, AND STEVEN N. WILLIAMS IN SUPPORT OF INDIRECT PURCHASER PLAINTFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

William V. Reiss, Daniel C. Hedlund, and Steven N. Williams, declare as follows:

1. William V. Reiss, a partner at Robins Kaplan LLP, Daniel C. Hedlund, a partner

at Gustafson Gluek PLLC, and Steven N. Williams, a partner at The Joseph Saveri Law Firm

LLP are duly licensed attorneys. They are each admitted pro hac vice to practice before this

Court, and they were appointed Interim Co-Lead Counsel (ECF No. 8) and their firms were

appointed Settlement Class Counsel (ECF No. 340) for the Indirect Purchaser Plaintiffs (“IPPs”)

in the above-captioned action (“Action”).

2. Settlement Class Counsel and the firms working at their direction in this case

(“IPP Class Counsel”) are working on a contingent fee basis, and without any guarantee of

compensation or reimbursement for time and expenses they have devoted to this Action beginning in February 8, 2018.

3. Antitrust class actions are among the most difficult and complex actions to prosecute, with indirect purchaser actions presenting their own additional set of challenges. IPP

Class Counsel represent nearly 30 class representatives and asserted a number of claims under both federal and state antitrust, consumer protection, and unjust enrichment laws on behalf of a

class of consumers and businesses that indirectly purchased Interior Molded Doors not for resale. 1

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4. Since December 26, 2018, IPP Class Counsel, at the direction of Settlement Class

Counsel, have devoted significant time to this litigation. To date, their activities have included:

• Performing extensive research into the IMDs and Doorskins industries, as well as the federal antitrust laws and the antitrust, consumer protection, and unjust enrichment laws of 32 states and the District of Columbia;

• Successfully opposing two motions to dismiss filed by Defendants through extensive briefing and oral argument before the Court;

• Spearheading the drafting and negotiation of discovery plans, protocols, a stipulated protective order and numerous stipulations with Defendants;

• Drafting and coordinating discovery against Defendants in conjunction with Direct Purchaser Plaintiffs (“DPPs”), followed by extensive meet and confers with each Defendant;

• Reviewing and analyzing approximately two million pages of documents produced by Defendants and non-parties;

• Developing a database to analyze voluminous telephone records;

• Preparing for and defending 29 class representative depositions;1

• Preparing for, taking, and/or participating in the depositions of 15 Defendant witnesses and three non-party witnesses;

• Consulting with IPPs’ expert economist to analyze Defendants’ transactional data and other information produced in discovery and through publicly available sources to

1 Each of the 28 class representatives named in the Settlement Agreement was deposed. (ECF No. 226-1). In addition, Defendants deposed former class representative Caryn Yost. Ms. Yost’s claims were voluntarily dismissed on January 7, 2020. (ECF No. 148).

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develop opinions relating to antitrust impact and damages for purposes of class certification, summary judgment, and trial;

• Working at length with a survey expert to respond to a fourth expert report served by Defendants;

• Preparing for and defending three depositions of IPPs’ experts;

• Preparing for and taking the depositions of four of Defendants’ experts;

• Performing numerous tasks necessary to achieve the Settlement,2 including: analyzing economic evidence and data and formulating settlement demands; engaging in extensive arm’s-length negotiations with Defendants; negotiating and preparing drafts of the Settlement Agreement; and preparing the preliminary approval motion and escrow agreement for the Settlement; and

• Crafting, in consultation with IPPs’ class-notice and claims administration expert, an extensive notice program and claims administration process that was approved by the Court.

5. The Settlement was reached after litigation was well underway and was negotiated by experienced counsel on all sides. At that point in the litigation, counsel on each side had a strong understanding of the case and the strengths and weaknesses of the claims and defenses asserted. The Settlement is the result of arm’s length negotiations by the parties, which took months and involved numerous discussions.

6. IPP Class Counsel have dedicated many thousands of attorney and staff hours and millions of dollars to the prosecution of this Action. Settlement Class Counsel closely monitored

2 Unless otherwise set forth herein, all defined terms shall have the same meaning as set forth in the Settlement Agreement executed on September 4, 2020. (ECF No. 226-1).

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and coordinated the efforts of nationwide counsel representing IPPs to maximize efficiency,

minimize duplication of efforts and costs, and eliminate unnecessary billing.

7. Settlement Class Counsel and the firms working under their direction have

invested an extraordinary amount of time and money in prosecuting this litigation that they could

have devoted to other matters, and have not been compensated for any of their work.

I. Award of Attorneys’ Fees

8. Settlement Class Counsel respectfully request a fee award of 30% of the

Settlement Fund, which equals $5,850,000, plus interest. As reflected in the authority cited in the

accompanying Memorandum of Law, this percentage is within the range of fees awarded by

other courts, both inside and outside the Fourth Circuit, in highly complex class actions of this

nature.3

9. When IPP Class Counsel undertook this litigation, it was with the knowledge that

millions of dollars in professional time and expenses would likely be spent litigating against

sophisticated and well-funded Defendants, represented by top-notch defense counsel, with no

assurance of obtaining any recovery for the class or related compensation for themselves.

Further, IPP Class Counsel did not have the benefit of a prior governmental action, and

Settlement Class Counsel led this case from the outset on a “private attorney general” basis.

10. IPP Class Counsel have received no compensation over the course of this

litigation. Their fees and reimbursement of expenses are totally contingent and dependent on awards by this Court.

3 A copy of the unpublished opinion cited in the accompanying Memorandum is attached hereto as Exhibit C. 4

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11. Based on a detailed and manual line-by-line review of all time submissions, including their own, Settlement Class Counsel determined that the total hours of work that reasonably benefited the Settlement Class is 27,848.16 and IPP Class Counsel’s total aggregate lodestar from the inception of the case on February 8, 20184 through February 28, 2021 is

$13,607,313. This lodestar is based on IPP Class Counsel’s historical rates rather than current rates. Settlement Class Counsel’s fee request represents a negative multiplier of approximately

.43.

12. Exhibit A summarizes the lodestar and total hours incurred by IPP Class Counsel

from February 8, 2018 through February 28, 2021 and certain costs and litigation expenses

incurred by IPP Class Counsel in pursuing the claims in this litigation from February 8, 2018

through March 31, 2021.

13. Exhibit A contains 22 declarations of IPP Class Counsel, including Liaison

Counsel for the Settlement Class, as well as three additional declarations from Settlement Class

Counsel, each of whom who performed services for IPPs and/or incurred costs and expenses

during the periods set forth above. The detailed time records for each firm will be made available

to the Court for in camera review should the Court request.

14. IPP Class Counsel’s hourly rates are in line with market rates and reflect rates

similar to those reported by IPP Class Counsel on a usual and customary basis by the IPP Class

Counsel firms for their services.

15. Pursuant to the Court’s December 26, 2018 Scheduling Order (ECF No. 8),

Settlement Class Counsel directed IPP Class Counsel to keep contemporaneous time and expense

4 “Inception” refers to February 8, 2018, the date upon which IPP Class Counsel first began investigating the claims at issue in this litigation. 5

Case 3:18-cv-00850-JAG Document 349-1 Filed 05/03/21 Page 6 of 9 PageID# 11192

records and to only undertake work at the direction of Settlement Class Counsel. Further,

Settlement Class Counsel directed IPP Class Counsel to submit monthly time and expense

reports and provided IPP Class Counsel with specific instructions regarding what time may be

submitted to the Court and how such time must be recorded. Settlement Class Counsel have

closely monitored the work of IPP Class Counsel to ensure efficiency and avoid unauthorized

and unnecessary work. All detailed time and expense records submitted by IPP Class Counsel

have been reviewed and vetted by Settlement Class Counsel. Settlement Class Counsel have

excluded time incurred in this litigation that did not provide a common benefit to the Settlement

Class, or that was not performed at the direction of Settlement Class Counsel.

16. Throughout this case, Settlement Class Counsel have sought to ensure the

efficient conduct of this litigation. Settlement Class Counsel’s extensive experience in

prosecuting complex antitrust class actions proved invaluable in enabling them to identify key

issues, to marshal the evidence in support of IPPs’ claims, and to devise strategies to guide the

litigation to a successful conclusion for the class. Settlement Class Counsel believe that the

settlement was the result of IPP Class Counsel’s experience, persistence, skill, and mastery of the evidence.

17. Settlement Class Counsel sought to avoid duplication of effort by delegating assignments among IPP Class Counsel. Settlement Class Counsel also sought to prepare for depositions and draft pleadings and briefs, among many other tasks, in an efficient and organized fashion, including coordinating, where appropriate, with counsel for the DPPs.

18. Additionally, Settlement Class Counsel capped the hourly billing rate for attorneys conducting document review at $300, which is in the range of document review billing

Case 3:18-cv-00850-JAG Document 349-1 Filed 05/03/21 Page 7 of 9 PageID# 11193

rates in similar cases, and can be substantially lower than the rate at which those attorneys are

ordinarily billed.

19. Even now, the work on this litigation will continue until the settlement fund is

finally distributed to Settlement Class Members. Settlement Class Counsel will continue to

expend many additional hours preparing for the Fairness Hearing scheduled on July 13, 2021,

and in connection with the ongoing claims administration process.

II. Award of Expenses and Costs

20. Settlement Class Counsel also seek reimbursement of $3,511,815.63 in costs and expenses from February 8, 2018 through March 31, 2021. This figure reflects: (1) $2,488,377.46 in common litigation costs and expenses that have been paid from the Litigation Fund; and (2)

$733,712.31 in additional common litigation costs and expenses that have been invoiced yet remain to be paid; and (3) costs incurred by IPP Class Counsel related to the prosecution of the litigation, excluding contributions to the Litigation Fund.5

21. These costs and expenses are associated with professional and consulting

services, document collection, third party subpoenas, deposition services, and transcripts.

22. IPP Class Counsel incurred millions of dollars in expenses to prosecute this

Action, and have not been reimbursed for any of their costs and expenses.

III. Request for Service Awards to Class Representatives

23. Settlement Class Counsel are also seeking approval to pay each remaining named

Plaintiff an incentive award.

5 Details regarding Litigation Fund expenditures are included in the Declaration of William V. Reiss Regarding the Litigation Fund in Support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the Class Representatives, attached hereto as Exhibit B. 7

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24. Settlement Class Counsel seek approval for $1,000 in service awards for each

class representative. IPPs are not seeking a service award for Plaintiffs who were dismissed from

the case.

25. The requested incentive awards total $28,000. This represents approximately

.14% of the Settlement Fund, a figure that is well in line with service awards granted in other

cases in the Fourth Circuit.

26. The class representatives expended substantial time and effort in assisting IPP

Class Counsel with the prosecution of the Settlement Class’s claims. The class representatives

invested significant time responding to discovery requests, including several sets of requests for

production and interrogatories and preparing for and attending depositions. Settlement Class

Counsel believe that the requested awards are fair and reasonable in light of Plaintiffs’ efforts

securing a significant benefit for the class, the substantial risks they took in filing suit, and the

critical role they played in enforcing the nation’s antitrust laws.

Case 3:18-cv-00850-JAG Document 349-1 Filed 05/03/21 Page 9 of 9 PageID# 11195

We declare under penalty of perjury under the laws of the United States that the

foregoing is true and correct.

Executed this 3rd day of May, 2021, in New York, New York.

/s/ William V. Reiss William V. Reiss Robins Kaplan LLP

Executed this 3rd day of May, 2021, in Minneapolis, Minnesota.

/s/ Daniel C. Hedlund Daniel C. Hedlund Gustafson Gluek PLLC

Executed this 3rd day of May, 2021, in San Francisco, California.

/s/ Steven N. Williams Steven N. Williams The Joseph Saveri Law Firm LLP

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 1 of 228 PageID# 11196

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 2 of 228 PageID# 11197

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG ANTITRUST LITIGATION

SUMMARY OF FIRM LODESTAR AND EXPENSES

Exhibit Firm Hours Lodestar Expenses A-1 Gustafson Gluek PLLC 4,315.7 $2,476,485.00 $644,152.60 A-2 Robins Kaplan LLP 6,099.0 $3,404,412.00 $668,741.85 A-3 The Joseph Saveri Law Firm LLP 6,089.5 $2,812,261.50 $775,406.89 A-4 Willcox & Savage, P.C. 630.16 $300,094.00 $2,718.74 A-5 Ademi LLP 917.8 $351,028.00 $61,581.20 A-6 Bonnett, Fairbourn, Friedman & Balint, P.C. 16.4 $11,080.00 $5,028.40 A-7 The Brualdi Law Firm, P.C. 458.2 $137,460.00 $30,000.00 A-8 Dampier Law Firm, P.C. 1,400.0 $452,034.00 $81,307.03 A-9 Edelson & Associates, LLC 1,012.2 $383,255.00 $75,075.00 A-10 Emerson Firm, PLLC 69.2 $48,038.00 $18,315.38 A-11 Fisher Law Office, PLLC 26.2 $5,940.00 $0 A-12 Frankovitch, Anetakis, Simon, Decapio & Pearl LLP 16.9 $5,840.00 $5,000.60 A-13 Goldman, Scarlato & Penny P.C. 834.5 $345,053.00 $70,256.68 A-14 Grabar Law 639.4 $201,957.50 $30,075.00 A-15 Greg Coleman Law 559.9 $197,625.00 $52,198.54 A-16 Hartley LLP 710.3 $250,436.50 $41,263.71 A-17 Hellmuth & Johnson PLLC 1085.0 $606,311.00 $63,770.17 A-18 Johnson Firm 438.9 $142,077.50 $20,000.00 A-19 Karon LLC 23.5 $19,740.00 $0 A-20 The Miller Law Firm, PC 194.2 $87,227.50 $35,068.36 A-21 Sharp Law LLP 78.9 $50,465.00 $10,094.84 A-22 Straus & Boies, LLP 1,114.5 $654,847.00 $18,087.06 A-23 Whitfield Bryson LLP 216.9 $72,600.00 $15,889.61 A-24 Wyatt & Blake, L.L.P. 135.7 $75,100.00 $11,106.05 A-25 Zelle LLP 765.2 $515,945.50 $42,965.61 Total 27,848.16 $13,607,313.00 $2,778,103.32

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Exhibit A-1 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 4 of 228 PageID# 11199

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF DANIEL C. HEDLUND IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Daniel C. Hedlund, hereby declare as follows:

1. I am a duly licensed attorney in Minnesota and am admitted pro hac vice in this

Court. I am a partner at Gustafson Gluek PLLC. On December 26, 2018, the Court appointed me

as one of Interim Co-Lead Counsel in the above-captioned action (“Action”), and on February 5,

2021, my firm was appointed Settlement Class Counsel along with Robins Kaplan LLP and Joseph

Saveri Law Firm. I submit this declaration in support of Indirect Purchaser Plaintiffs’ Motion for

an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the Class

Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has served as Interim Co-Lead Counsel and Settlement Class Counsel for

the Indirect Purchaser Plaintiffs in this litigation on an entirely contingent basis. The background

and experience of Gustafson Gluek and its attorneys are summarized in the firm resume attached

hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’ Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 5 of 228 PageID# 11200

fee lodestar in this litigation. This includes work performed by my firm’s attorneys and

professional staff, computed at my firm’s historical hourly rates from inception through February

28, 2021.

5. The total number of hours expended in this litigation by my firm from inception

through February 28, 2021 is 4,315.7. The total lodestar for my firm is $2,476,485.00 The total

attorney and professional staff time reflected in this declaration is based on my firm’s

contemporaneous, daily time records regularly prepared and maintained by my firm, as well as

any reductions applied to avoid duplication and ensure efficiency.

6. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $644,152.60 in

unreimbursed costs and expenses in this litigation during the period from February 28, 2018

through March 31, 2021, including $612,000.00 in contributions to the Indirect Purchaser

Plaintiffs’ joint litigation fund. My firm advanced these costs and expenses with no assurance that

such costs and expenses would be repaid.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 6 of 228 PageID# 11201

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 30th day of April, 2021, in Minneapolis, Minnesota.

Daniel C. Hedlund GUSTAFSON GLUEK PLLC

3 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 7 of 228 PageID# 11202

EXHIBIT A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 8 of 228 PageID# 11203

Firm Resume

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 9 of 228 PageID# 11204

Table of Contents

I. Firm Overview...... 3

II. Leadership Positions...... 4

III. Case Outcomes...... 6

IV. Practice Areas and Current Cases...... 13

• Antitrust Litigation...... 13

• Appellate Advocacy...... 15

• Constitutional Litigation...... 17

• Consumer Protection...... 19

• Data Breach Litigation...... 20

• Intellectual Property & Patent Misuse Litigation...... 22

• Products Liability Litigation...... 23

• Securities Litigation...... 25

V. Pro Bono & Community...... 26

VI. Our Professionals...... 28

120 South Sixth Street, Suite 2600 Minneapolis, MN 55402

p. 612-333-8844 f. 612-339-662

gustafsongluek.com

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Firm Overview

Gustafson Gluek PLLC is an 18-attorney law firm with a national practice specializing in complex litigation. We have offices in Minneapolis, Minnesota and San Diego, California. At Gustafson Gluek, we seek to vindicate the rights of, and recover damages for, those harmed by unfair business practices such as illegal price fixing, deceptive trade practices, and the distribution of unsafe medical devices, as well as enjoin companies from engaging in these types of practices in the future.

Founded in 2003, Gustafson Gluek’s attorneys have consistently been recognized by their clients, peers, and courts across the country as leaders in their fields and, as such, have been chosen to lead some of the largest and most complex multi-district litigations. Attorneys at Gustafson Gluek have received national and state-wide awards and honors, and are routinely called upon by other leading firms to assist in taking on some of the largest companies and defense firms in the world. Gustafson Gluek was named in the Top 25 Lead Counsel in Antitrust Complaints filed from 2009 – 2019 in the 2019 Antitrust Annual Report produced by the University of San Francisco Law School and The Huntington National Bank. We were also listed as number seven in the list of firms who have filed antitrust cases, having filed 190 antitrust actions during that same time period. Also, according to that same report, in that 2009-2019 time period, Gustafson Gluek helped recover over $707 million for class members in 48 different antitrust cases.

Gustafson Gluek strongly believes in giving back to the community and promoting diversity in the legal profession. Its attorneys have held leadership positions and actively participate in numerous national, state and affinity legal organizations, including the Federal Bar Association, Minnesota State Bar Association, the Infinity Project, Minnesota Women Lawyers, Minnesota Asian Pacific American Bar Association, and American Antitrust Institute. Gustafson Gluek was instrumental in founding the Pro Se Project, a collaboration with the Minnesota District Court pairing indigent federal litigants with attorneys and Gustafson Gluek devote hundreds of hours each year to pro bono service through the Pro Se Project and other organizations.

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Leadership Positions

Gustafson Gluek’s attorneys are frequently recognized by their peers and the Courts as experienced and capable leaders and, as such, have been appointed to lead numerous complex litigations including the following:

In re Google Digital Publisher Antitrust Litig. (N.D. Cal.) Plaintiffs’ Leadership Committee

In re Interior Molded Doors Indirect Purchaser Antitrust Litig. (E.D. Va.) Co-Lead Counsel

In re Pork Antitrust Litig. (D. Minn.) Co-Lead Counsel for Consumer Indirect Purchaser Plaintiffs

In re: 3M Combat Arms Earplug Litig. (Minn.) Co-Lead Counsel

In re DPP Beef Litig. (D. Minn.) Co-Lead Counsel

In re Dealer Management Systems Antitrust Litig. (N.D. Ill.) Plaintiffs’ Steering Committee

In re CenturyLink Residential Customer Billing Disputes Litig. (D. Minn.) Executive Committee Chair

In re Syngenta Litig. (Minn.) Co-Lead Class Counsel

In re Broiler Chicken Antitrust Litig. (N.D. Ill.) Co-Lead Counsel for Commercial and Institutional Indirect Purchaser Plaintiffs

Vikram Bhatia, D.D.S., et al., v. 3M Company (D. Minn.) Co-Lead Counsel

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In re Medtronic, Inc. Sprint Fidelis Leads Products Liability Litig. (D. Minn.) Lead Counsel

In re DRAM Antitrust Litig. (N.D. Cal. and multiple state court actions) Co-Lead Counsel for Indirect Purchasers

In re Medtronic, Inc. Implantable Defibrillators Products Liability Litig. (D. Minn.) Co-Lead Counsel

St. Barnabas Hospital, Inc. et al. v. Lundbeck, Inc. et al. (D. Minn.) Interim Class Counsel

In re Vitamin C Antitrust Litig. (E.D.N.Y.) Co-Lead Counsel for Indirect Purchasers

In re Flash Memory Antitrust Litig. (N.D. Cal.) Plaintiffs’ Steering Committee

Precision Assocs., Inc. v. Panalpina World Transport (Holding) Ltd. (E.D.N.Y.) Co-Lead Counsel

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Case Outcomes

Gustafson Gluek has recovered billions of dollars on behalf of its clients since its founding in 2003. At Gustafson Gluek, we seek to vindicate the rights of, and recover damages for, those harmed by unfair business practices such as illegal price fixing, deceptive trade practices, and the distribution of unsafe or defective devices, as well as enjoin companies from engaging in these types of practices in the future. A list of representative cases we have previously litigated and the outcomes of those cases is set forth below.

ANTITRUST

In re Automotive Parts Antitrust Litigation (E.D. Mich.) Gustafson Gluek was an integral part of the team representing a class of indirect purchases of various automotive components. Plaintiffs alleged that the defendants engaged in a sprawling price fixing conspiracy to artificially increase the price of several different automobile components. Gustafson Gluek helped recover over $604 million for the class.

In re Capacitors Antitrust Litigation (N.D. Cal.) Gustafson Gluek represented a class of indirect purchasers of electrolytic or film capacitors. Plaintiffs alleged that at least fifteen multinational corporations conspired to fix the prices of capacitors that they manufactured and sold worldwide and into the United States. Gustafson Gluek attorneys worked closely with Lead Counsel throughout the litigation, which eventually recovered $84.49 million for the class.

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In re Cathode Ray Tube (CRT) Antitrust Litigation (N.D. Cal.) Gustafson Gluek represented a class of direct purchasers of CRT screens used for computer monitors and televisions. Plaintiffs alleged that defendants conspired to fix the price of these products in violation of the antitrust laws. Gustafson Gluek had a significant discovery role in the prosecution of this antitrust class action, which resulted in settlements totaling $225 million for the class.

In re DRAM Antitrust Litigation (N.D. Cal. and multiple state court actions) Gustafson Gluek was appointed Co-Lead Counsel for the indirect purchasers in this nationwide class action against both national and international memory- chip manufacturers. This case dealt with the conspiracy surrounding the pricing of the memory chips commonly known as Dynamic Random Access Memory (or DRAM). DRAM is used in thousands of devices on a daily basis, and Gustafson Gluek was integral in achieving a settlement of $310 million for the class.

In re Domestic Drywall Antitrust Litigation (E.D. Pa.) Gustafson Gluek represented a class of direct purchasers of drywall in this antitrust case. Plaintiffs alleged that the defendant manufacturers conspired to artificially increase the price of drywall. Gustafson Gluek played an active role in the litigation. A class was certified, and Gustafson Gluek helped recover over $190 million for the class.

In re Containerboard Antitrust Litigation (N.D. Ill.) Gustafson Gluek represented a class of direct purchasers of containerboard products and was a defendant team leader. Plaintiffs alleged that defendant containerboard manufacturers conspired to fix the price of containerboard. As team leader, Gustafson Gluek handled all aspects of discovery, including the depositions of several senior executives. Gustafson Gluek helped to secure over $376 million for the class.

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In re Lithium Ion Batteries Antitrust Litigation (N.D. Cal.) Gustafson Gluek represented a class of direct purchasers of lithium ion batteries in a multidistrict class action. Plaintiffs alleged collusive activity by the world’s largest manufacturers of lithium ion batteries, which are used in everything from cellular phones to cameras, laptops and tablet computers. Gustafson Gluek had a significant discovery role in the prosecution of this antitrust class and helped recover over $139 million for the class.

Precision Associates, Inc., et al. v. Panalpina World Transport (Holding) Ltd., et al. (E.D.N.Y.) Gustafson Gluek was Co-Lead Counsel representing a class of direct purchasers of freight forwarding services in this international case against 68 defendants. Plaintiffs alleged that defendants engaged in an international conspiracy to fix, inflate, and maintain various charges and surcharges for freight forwarding services in violation of U.S. antitrust laws. Gustafson Gluek worked to secure over $450 million for the class.

In re Resistors Antitrust Litigation (N.D. Cal.) Gustafson Gluek worked closely with Lead Counsel representing indirect purchasers of linear resistors. Plaintiffs alleged that the defendant manufacturers conspired to increase the price of linear resistors, thereby causing indirect purchasers to pay more. After engaging in extensive discovery, Plaintiffs recovered a total of $33.4 million in settlements for the indirect purchaser class.

In re TFT-LCD (Flat Panel) Antitrust Litigation (N.D. Cal.) Gustafson Gluek served an integral role handling complex discovery issues in this antitrust action representing individuals and entities that purchased LCD panels at supracompetitive prices. Gustafson Gluek attorneys worked on a range of domestic and foreign discovery matters in prosecuting this case. The total settlement amount with all of the defendants was over $1.1 billion.

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CONSUMER PROTECTION

Syngenta Corn Seed Litigation (Minn. & D. Kan.) Gustafson Gluek was appointed Co-Lead Counsel for the class of Minnesota corn farmers suing Syngenta for negligently marketing its Agrisure/Viptera corn seed before it had been approved in all of the major corn markets. Gustafson Gluek was an integral part of the litigation team in Minnesota, participating in all facets of discovery, motion practice and expert work. Dan Gustafson was one of the lead trial counsel and was also appointed as part of the settlement team. Ultimately, these cases settled for $1.51 billion on behalf of all corn farmers in America.

In re Centurylink Sales Practices and Securities Litigation (D. Minn.) Gustafson Gluek was Chair of the Executive Committee and represented a class of current and former CenturyLink customers who paid too much for their phone, internet or television services due to CenturyLink’s unlawful conduct. Plaintiffs alleged that CenturyLink engaged in deceptive marketing, sales, and billing practices across the dozens of states in which it does business by: (1) promising a discount or promotion that was never applied; (2) charging more for services than it advertised or otherwise promised; (3) charging for services it did not provide; (4) charging for services customers did not request; (5) charging undisclosed or higher-than-agreed upon fees; (6) charging improper terminations fees; and (7) putting customers into collections as a result of unpaid overcharges. Ultimately, Plaintiffs recovered $18.5 million in settlements for this class.

Yarrington, et al. v. Solvay Pharmaceuticals, Inc. (D. Minn.) Gustafson Gluek represented a class of individuals alleging unfair competition and false and deceptive advertising claims against Solvay Pharmaceuticals in the marketing of Estratest and Estratest HS, prescription hormone therapy drugs. Gustafson Gluek helped recover $16.5 million for the class.

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SECURITIES

St. Paul Travelers Securities Litigation I and II (D. Minn.) Gustafson Gluek served as liaison counsel in both of the St. Paul Travelers Securities Litigations. At issue in the cases were public statements as well as material omissions St. Paul Travelers made that negatively impacted the stock prices of the Company. On behalf of New Mexico State Funds, Gustafson Gluek worked to litigate the two separate class actions against St. Paul Travelers, resulting in multi-million-dollar settlements.

Smith v. Questar Capital Corp., et al. (D. Minn.) Gustafson Gluek represented a class of investors who were defrauded in a Ponzi scheme by a brokerage firm that sold bonds to sustain an entity that had collapsed into bankruptcy. Gustafson Gluek helped recover $3 million for the class of 125 investors.

PRODUCT LIABILITY

Bhatia v. 3M Co. (D. Minn.) Gustafson Gluek represented a class of dentists who bought 3M Lava Ultimate Restorative material for use in dental crowns. Gustafson Gluek was appointed as Co-Lead Counsel for Plaintiffs, who alleged that the 3M Lava material failed at an unprecedented rate, leading to substantial loss of time and money for the dentists and injury to the patients. Gustafson Gluek helped secure a settlement of approximately $50 million for all of the dentists who had suffered damages from the failure of this product.

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Medtronic, Inc., Sprint Fidelis Leads Products Liability Litigation (D. Minn.) Gustafson Gluek was Lead Counsel representing Plaintiffs, who had Medtronic’s Sprint Fidelis Leads implanted in them. Plaintiffs alleged that Medtronic’s Sprint Fidelis Leads contained serious defects that cause the leads to fracture, resulting in unnecessary shocks. Ultimately, these cases settled for over $200 million on behalf of thousands of injured claimants who participated in the settlement. The settlement included a seven year claim period in which individuals who were registered to participate in the settlement could make a claim if their device failed or was removed within that time period for reasons related to the alleged defect.

Medtronic, Inc. Implantable Defibrillators Products Liability Litigation (D. Minn.) Gustafson Gluek was appointed Co-Lead Counsel in this MDL representing individuals, who were implanted with certain implantable defibrillators manufactured by Medtronic, Inc. Plaintiffs alleged that these certain Medtronic’s implantable cardioverter defibrillators (ICDs), and cardiac resynchronization therapy defibrillators (CRT-Ds) contained serious battery defects, which resulted in a recall of the products at issue. Plaintiffs alleged that Medtronic, Inc. knew about this defect, intentionally withheld important information from the FDA and the public and continued to sell the devices for implantation into patients facing life-threatening heart conditions. Gustafson Gluek, in its role as Co-Lead Counsel, helped secure a settlement of approximately $100 million dollars for claimants who participated in the settlement.

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INTELLECTUAL PROPERTY & PATENT MISUSE

Augmentin Litigation (E.D. Va.) Gustafson Gluek represented a class of direct purchasers of the pharmaceutical drug, Augmentin. Plaintiffs alleged that defendant GlaxoSmithKline violated the antitrust laws by unlawfully maintaining its monopoly over Augmentin and preventing the entry of generic equivalents. Gustafson Gluek helped recover $62.5 million for the class.

Dryer, et al., v. National Football League (D. Minn.) The U.S. District Court for the District of Minnesota appointed Gustafson Gluek Lead Settlement Counsel in Dryer v. NFL. In that capacity, Gustafson Gluek represented a class of retired NFL players in protecting their rights to the use of their likenesses in marketing and advertising. Gustafson Gluek helped secure a settlement with the NFL that created unprecedented avenues of revenue generation for the class.

Spine Solutions, Inc., et al. v. Medtronic Sofamore Danek, Inc., et al. (W.D. Tenn.) Gustafson Gluek was one of the counsel representing the plaintiff, Spine Solutions, Inc. and Synthes Spine So., L.P.P., in a patent litigation against Medtronic Safamor Danek, Inc. and Medtronic Sofamor Donek, USA. The patent at issue in that case involved technology relating to spinal disc implants. This case went to trial in November 2008 and a jury verdict was returned in favor of our clients. The jury found willful infringements and awarded both lost profits and reasonable royalty damages to our clients.

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In re Wellbutrin SR Antitrust Litigation (E.D. Pa.) Gustafson Gluek played an integral role in this pharmaceutical class action. The firm represented direct purchasers of Wellbutrin SR, who alleged that defendant GlaxoSmithKline defrauded the U.S. Patent and Trademark Office and filed sham lawsuits against its competitors, which delayed the availability of the generic version of Wellbutrin SR to consumers. As a result of this delay, Plaintiffs alleged that they paid more for Wellbutrin SR than they would have if the generic version had been available to them. Gustafson Gluek was actively involved in the investigation, discovery, motion practice, and trial preparation for this case and served an essential role in the mediation that resulted in a $49 million settlement to the direct purchasers.

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Practice Areas and Current Cases

ANTITRUST LITIGATION Gustafson Gluek PLLC is devoted to the prosecution of antitrust violations. We have litigated antitrust cases in federal and state courts across the United States.

Federal and state antitrust laws are designed to protect and promote competition among businesses by prohibiting price fixing and other forms of anticompetitive conduct. Violations can range from straight forward agreements among competitors to raise prices above competitive prices to complicated schemes that affect relationships between different levels of a market.

Ongoing prosecution of these illegal schemes helps protect the average consumer from being forced to pay more than they should for everyday goods. Below are some representative antitrust cases that Gustafson Gluek is currently involved in:

In re Google Digital Publisher Antitrust Litigation (N.D. Cal.) Gustafson Gluek has been appointed to the Leadership Committee representing a class of publishers who sold digital advertising space via Google. Plaintiffs allege that Google’s anticompetitive monopolistic practices led to digital publishers being paid less for their advertising space than they otherwise would have been paid in a competitive market.

In re Broiler Chicken Antitrust Litigation (N.D. Ill.) Gustafson Gluek is part of the Co-Lead counsel team for class of commercial indirect purchasers. The case alleges chicken suppliers colluded to artificially restrict the supply and raise the price of chicken in the United States. As part of the co-lead counsel team, Gustafson Gluek helped successfully defeated defendants’ motion to dismiss. This case is on-going.

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In re Pork Antitrust Litigation (D. Minn.) Gustafson Gluek has been appointed as Interim Co-Lead counsel representing a class of consumers who purchased pork products. Plaintiffs allege pork producers, who control over 80% of the wholesale pork market in the U.S., conspired to fix prices by, among other things, agreeing to restrict production to artificially increase prices. Having survived motions to dismiss, discovery is now in progress.

In re Hard Disk Drive Suspension Assemblies Antitrust Litigation (N.D. Cal.) Gustafson Gluek represents a class of indirect purchaser end user plaintiffs who purchased products containing Hard Disk Drive (HDD) suspension assemblies. Plaintiffs allege that the defendant HDD suspension assemblies manufacturers unlawfully conspired to fix the prices of the HDD suspension assemblies and manufactured and sold the component worldwide and into the United States at an inflated price.

In re Disposable Contact Lens Antitrust Litigation (M.D. Fla.) Gustafson Gluek represents a class of individuals who purchased contact lenses made by Alcon, CooperVision, Bausch + Lomb, and Johnson & Johnson. Plaintiffs allege that these manufacturers unlawfully conspired to impose minimum resale price agreements on retailers, which restricts retailers’ ability to lower prices to consumers. The class has been certified and discovery is ongoing.

In re Blue Cross Blue Shield Antitrust Litigation (N.D. Ala.) Gustafson Gluek has been appointed as members of the Damages and Litigation Committees representing a class of subscribers of Blue Cross Blue Shield Alabama. Plaintiffs allege antitrust violations by the defendant. Plaintiffs’ counsel recently reached a settlement for $2.7 billion on behalf of the class.

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In re Interior Molded Doors Indirect Purchaser Antitrust Litigation (E.D. Va.) Gustafson Gluek has been appointed as Interim Co-Lead Counsel with two other firms representing a class of indirect purchasers of interior molded doors. Plaintiffs allege that two of the country’s largest interior molded door manufacturers conspired to inflate prices in the market. Plaintiffs’ counsel recently settled the case with defendants for $19.5 million on behalf of the class.

In re Dealer Management Systems Antitrust Litigation (N.D. Ill.) Gustafson Gluek has been appointed as a member of the Steering Committee representing a class of car dealerships. Plaintiffs allege that defendants unlawfully entered into an agreement that reduced competition and increased prices in the market for Dealer Management Systems (“DMS”) and data integration services related to DMS. Plaintiffs have reached a settlement with one defendant but continue to litigate against the remaining defendants.

In re DPP Beef Litigation (D. Minn.) Gustafson Gluek has been appointed Co-Lead Counsel for a proposed class of direct purchasers of beef. Plaintiffs allege that Cargill JBS, Tyson and National Beef Packing Company conspired to fix and maintain the price of beef in violation of the federal antitrust laws resulting in supracompetitive prices for beef. This litigation is ongoing.

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APPELLATE ADVOCACY Our attorneys are just the experienced, seasoned appellate advocates that can assist in getting the right result. Because we have tried complex cases to jury and bench verdicts, we understand how important the trial court is to a successful appeal.

Gustafson Gluek’s appellate attorneys draw from our years of experience practicing before courts at every level of the state and federal system. We have successfully briefed and argued a variety of complex class and non-class cases and been called upon by peers to assist in the appellate process for their clients as well. In addition, we have frequently written briefs and appeared as amicus curiae (friend of the court) on behalf of several professional organizations.

Our appellate attorneys are admitted to practice in the following appellate courts:

• First Circuit Court of Appeals

• Third Circuit Court of Appeals

• Fifth Circuit Court of Appeals

• Eighth Circuit Court of Appeals

• Ninth Circuit Court of Appeals

• Eleventh Circuit Court of Appeals

• Minnesota State Court of Appeals

• Minnesota Supreme Court

• United States Supreme Court

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Some of the cases we have argued before the Eighth Circuit include:

• Karsjens, et al. v. Piper, et al.

• LaBrier v. State Farm Fire and Casualty Co.

• MN Senior Foundation, et al. v. United States, et al.

• Wallace James Beaulieu v. State of Minnesota

• Anna Bryant, et al. v. Medtronic, Inc., et al.

• Jeanette Rick, et al. v. Wyeth, Inc., et al.

• Dryer, et al. v. National Football League

• Smith v. Fairview Ridges Hospital

• Morgan Larson v. Ferrellgas Partners

CONSTITUTIONAL LITIGATION Gustafson Gluek is devoted to the protection of the constitutional liberties of all individuals. We have litigated several cases at the federal court level on matters involving civil commitment, police brutality, prisoner mistreatment and government misuse of private property. Below are some representative cases involving constitutional claims that Gustafson Gluek is currently litigating or has recently litigated:

Doe v. Hanson et al. (Minn.) Gustafson Gluek represents a former juvenile resident of Minnesota Correctional Facility – Red Wing who alleges he was sexually assaulted by a staff member over the course of several years. Despite alleged knowledge of the risk of the abuse to the juvenile, the Correctional Facility did nothing to protect the juvenile. A settlement was reached in 2021, which included significant financial compensation for the victim, required additional training for the MCF-Red Wing staff, and 3 policy changes at MCF-Red Wing.

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Carr v. City of Robbinsdale (Minn.) Gustafson Gluek represented an individual whose car was seized by the Robbinsdale police. Our client was a passenger in her car, when the driver was pulled over and arrested for driving under the influence. The officer seized the car pursuant to Minnesota’s civil forfeiture statute. Gustafson Gluek filed a complaint challenging the constitutionality of the Minnesota civil forfeiture laws. However, prior to any meaningful litigation, the parties were able to settle the case.

Khottavongsa v. City of Brooklyn Center (D. Minn.) Gustafson Gluek represented the family of a man killed by Brooklyn Center police in 2015. Gustafson Gluek brought section 1983 claims, alleging the officers used excessive force and ignored his medical needs, and that the City of Brooklyn Center failed to train and supervise the officers. Defendant’s motion for summary judgment was largely defeated. The case settled prior to trial.

Hall v. State of Minnesota (Minn.) Gustafson Gluek successfully litigated a case against the State of Minnesota regarding the State’s Unclaimed Property Act. On behalf of Plaintiffs, the Firm achieved a ruling that a portion of the State’s Unclaimed Property Act was unconstitutional and, as a result, the statute was changed, and property returned to individuals.

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Karsjens, et al. v. Jesson, et al. (D. Minn.) Gustafson Gluek represents a class of Minnesota’s civilly committed sex offenders on a pro bono basis through the Federal Bar Association’s Pro Se Project. Gustafson Gluek has been litigating this case since 2012, alleging that Minnesota’s civil commitment of sex offenders is unconstitutional and denies the due process rights of the class. After a six-week trial in February and March of 2015, Minnesota District Court Judge Donovan Frank found in favor of the class, ruling that the Minnesota Sex Offender Program (MSOP) is unconstitutional, and ordering that extensive changes be made to the program. That order was reversed on appeal. Gustafson Gluek continues to vigorously advocate for the class on the remaining claims and pursue a resolution that will provide constitutional protections to those civilly committed to the MSOP.

Jihad v. Fabian (D. Minn.) Gustafson Gluek represented an individual bringing suit against the State of Minnesota, the Department of Corrections and others alleging violations of his religious rights relating to his incarcerations in the Minnesota Corrections Facility in Stillwater. Gustafson Gluek was able to secure a settlement for the plaintiff which involved a change in the Department of Corrections policy to provide plaintiff with halal-certified meals at the correction facilities.

Samaha, et al. v. City of Minneapolis, et al. (D. Minn.) Gustafson Gluek is representing several peaceful protestors who were subject to excessive force at the George Floyd protests in May 2020. While peacefully protesting, the plaintiffs were subjected to tear gas, pepper spray and other violence. The case is a class action seeking declaratory and injunctive relief, including a judgment that the City of Minneapolis has a custom, policy and practice of encouraging and allowing excessive force. The case is on-going.

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CONSUMER PROTECTION LITIGATION Gustafson Gluek PLLC has led class action lawsuits on behalf of consumers alleging consumer protection violations or deceptive trade practices. These cases involve claims related to the false marketing of life insurance, defective hardware in consumer computers, misleading air compressor labeling, and rental car overcharges. Below are some representative cases involving consumer protection claims that Gustafson Gluek is currently litigating:

Big Heart Pet Brands Litigation (N.D. Cal.) Gustafson Gluek represents a class of individuals who purchased Gravy Train dog food. Plaintiffs allege that the defendant’s packages were misleading due to the presence of the euthanasia drug, pentobarbital, found in the dog food at issue.

Champion PetFoods Litigation (multi-state actions) Gustafson Gluek represents consumers who purchased Orijens and/or Acana brands of Champion PetFoods. Plaintiffs have brought cases in several states, including California, Minnesota, Illinois, Colorado, Wisconsin, Massachusetts and Iowa alleging that Champion PetFoods makes misrepresentations and omissions on their packaging of these dog foods.

Hudock v. LG Electronics USA, Inc. (D. Minn.) Gustafson Gluek represents a class of consumers who purchased certain LG LED televisions during the relevant time period. Plaintiffs bring this action against LG Electronics USA, Inc. and Best Buy, alleging that certain LG LED televisions were marketed and advertised with a misleading refresh rate specification. The district court has granted Plaintiffs’ motion to certify a nationwide class of purchasers of these televisions.

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Thomas et al. v. Beech-Nut Nutrition Co. (N.D.N.Y.); McKeon et al. v. Plum, PBC and Plum, Inc. (N.D. Cal.); McKeon et al. v. Hain Celestial Group, (E.D.N.Y.); Hampton et al. v. Nuture, Inc. (S.D.N.Y.) Gustafson Gluek represents proposed nationwide classes of consumers that purchased Beech-Nut, Plum Organics, Earth’s Best Organics, and HappyBaby or HappyTot baby foods. Plaintiffs allege that these baby foods were deceptively marketed and sold because they contain undisclosed levels of heavy metals, including lead, cadmium, mercury and arsenic.

DATA BREACH LITIGATION Data breaches on the internet and at point-of-sale terminals are an increasing concern for consumers and businesses alike. Data breaches can result in the loss of payment card data, as well as personally identifiable information. This can result in financial loss, identity theft, and privacy concerns.

Gustafson Gluek represents consumers and financial institutions in class actions seeking compensation, changes to data practices, and other relief for injured parties under federal and state law. Below are some representative cases that Gustafson Gluek is currently litigating or has recently litigated:

Marriott International, Inc., Customer Data Security Breach Litigation (D. Md.) Gustafson Gluek represents a class of consumers whose personally identifiable information, including passport information, customers' names, mailing address, and payment card numbers, as well as other highly-sensitive personal data, was compromised as the result of Marriott’s and its merger partner, Starwood Hotels & Resort Worldwide, LLC's deficient data security practices. Many of these consumers have lost time and money responding to the data breach, and they face an ongoing risk of identity theft, identity fraud, or other harm.

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In re Equifax Inc. Customer Data Security Breach Litigation (N.D. Ga.) Gustafson Gluek represented Plaintiffs whose personal information was impacted as the result of the Equifax’s deficient data security practices. Plaintiffs reached a settlement where Equifax agreed to pay $380 million towards the fund for class benefits and an additional $125 million for out-of-pocket losses in addition to credit monitoring and identity restoration services. This settlement was approved by the court in January 2020.

Landwehr v. AOL Inc. (E.D. Va.) Gustafson Gluek served as class counsel in this lawsuit, alleging that AOL made available for download its members’ search history data, which violated these AOL members’ right to privacy under the Federal Electronic Communications Privacy Act. Plaintiffs reached a settlement with AOL that made $5 million available to pay the claims of class members whose search data was made available for download by AOL.

The Home Depot, Inc., Customer Data Security Breach Litigation (N.D. Ga.) Gustafson Gluek represented credit unions and a class of financial institutions whose card members’ payment data was compromised as the result of Home Depot’s deficient data security practices. These financial institutions lost time and money responding to the data breach. Plaintiffs reached a settlement agreement with Home Depot for $27.25 million for the class members.

Greater Chautauqua Federal Credit Union v. Kmart Corporation (N.D. Ill.) Gustafson Gluek served on the court-appointed Plaintiffs’ Steering Committee representing a class of financial institutions whose card members’ payment data was compromised as a result of Kmart’s deficient data security practices. These financial institutions lost time and money responding to the data breach. Plaintiffs reached a $5.2 million settlement with K-Mart for the class.

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Experian Data Breach Litigation (C.D. Cal.) Gustafson Gluek represented a class of consumers whose personally identifiable information, including Social Security numbers and other highly-sensitive personal data, was compromised as the result of Experian’s deficient data security practices. Many of these consumers lost time and money responding to the data breach, and they face an ongoing risk of identity theft, identity fraud, or other harm. Plaintiffs reached a $22 million settlement and as a part of the settlement, defendants also agreed and have begun undertaking certain remedial measures and enhanced security measures, which they will continue to implement, valued at over $11.7 million.

INTELLECTUAL PROPERTY & PATENT MISUSE LITIGATION Gustafson Gluek represents companies or individuals in asserting or protecting their intellectual property or publicity rights. They have represented patent holders against companies that are infringing the patent rights of our clients. For example, Gustafson Gluek has assisted in the prosecution of patent infringement claims involving medical devices and technology used in printing machines. They have also represented individuals whose publicity rights have been infringed.

Sometimes, however, a patent holder will attempt to abuse its exclusive rights by illegally obtaining or extending a patent. Gustafson Gluek has extensive experience in litigating cases alleging patent misuse. Often this type of patent misuse is found in the pharmaceutical industry, where a brand name pharmaceutical manufacturer will attempt to keep generic drugs off the market by unlawfully extending the life of its patent by committing fraud on the patent office or bringing sham litigation against generic manufacturers for patent infringement. The attorneys at Gustafson Gluek are actively involved in cases involving claims of patent abuse. Below are some representative patent misuse cases that Gustafson Gluek is currently litigating:

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In re Remicade Antitrust Litigation (E.D. Pa.) Gustafson Gluek represents a proposed class of End-Payor Plaintiffs in this antitrust class action. Plaintiffs allege anticompetitive conduct by defendants Johnson & Johnson and Jassen Biotech, Inc. in the biosimilars market. Discovery is ongoing in this litigation.

In re Restasis (Cyclosporine Opthalmic Emulsion) Antitrust Litigation (E.D.N.Y.) Gustafson Gluek represents a proposed class of End-Payor Plaintiffs in this antitrust class action. Plaintiffs allege that defendant Allergan engaged in a multifaceted conspiracy to delay generic competition for its brand-name drug Restasis. Motions for class certification in this matter are pending.

In re Opana ER Antitrust Litigation (N.D. Ill.) Gustafson Gluek represents a proposed class of End-Payor Plaintiffs in this antitrust class action. Plaintiffs allege that defendants, Endo Pharmaceuticals Inc., Endo Health Solutions Inc., Penwest Pharmaceuticals Co. (collectively, “Endo”), and Impax Laboratories, Inc., engaged in anticompetitive conduct to keep generic alternatives to Opana ER off the market.

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PRODUCTS LIABILITY LITIGATION Sometimes, consumers are injured by the products they purchase. Products liability is an area of law that seeks to hold manufacturers of products that have injured individuals responsible for the injuries their defective products caused. These defective products range from medical devices to vehicles to diapers and many others. Gustafson Gluek PLLC represents consumers against the manufacturers of these defective products and has been able to achieve sizable recoveries on behalf of injured individuals. Below are some representative product liability cases that Gustafson Gluek is currently litigating:

Graves v. 3M Co. (D. Minn. / Minn. State Court) Gustafson Gluek represents civilians who purchased and used the 3M/Aero manufactured dual-sided earplugs for use in both job and recreational endeavors and who have since experienced hearing loss and tinnitus. Plaintiffs allege that the Defendant failed to properly instruct Plaintiffs on how to use these devices.

In re FCA US LLC Monostable Electronic Gearshift Litigation (E.D. Mich.) Gustafson Gluek serves on the Plaintiffs’ Steering Committee and represents individuals who owned or leased 2012-2014 Dodge Chargers, 2014-2015 Chrysler 300s, and 2014-2015 Jeep Grand Cherokees. Plaintiffs allege that these vehicles contain defective gearshifts, which allow vehicles to roll away out of the park position. Issue classes have been conditionally certified.

Krautkramer et al., v. Yamaha Motor Corporation, U.S.A. (D. Minn.) Gustafson Gluek represents a proposed class of individuals who own or lease a range of Yamaha off-road vehicles. Plaintiffs allege that these vehicles are subject to overheating and engine failure due to a defect in the vehicle engines.

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Reynolds, et al., v. FCA US, LLC (E.D. Mich.) Gustafson Gluek represents a proposed class of individuals who owned or leased 2018-2020 Jeep Wrangler and 2020 Jeep Gladiator vehicles. Plaintiffs allege that these vehicles contain a defective front axle suspension system that causes the steering wheel to shake violently while operating at highway speeds.

Rice v. Electrolux Home Prod., Inc. (M.D. Pa.); Gorczynski v. Electrolux Home Products, Inc. (D.N.J.) Gustafson Gluek represents classes of individuals who own an Electrolux microwave with a stainless steel handles. Plaintiffs in these cases allege that these certain microwaves, which were sold to be placed over a cooktop surface, have stainless steel handles that can heat to unsafe temperatures when the cooktop below is in use.

Woronko v. General Motors, LLC (E.D. Mich.) Gustafson Gluek represents a proposed class of individuals who owned or leased 2015-2016 Chevrolet Colorado and GMC Canyon vehicles. Plaintiffs allege that these vehicles are equipped with a defective electrical connection that causes the vehicles to lose power steering while driving under a variety of conditions. This case is in the initial pleading stage.

SECURITIES LITIGATION Federal laws allow shareholders the right to bring a private action to recover damages the shareholder sustained as a result of securities fraud. Gustafson Gluek PLLC has worked with institutional investors and has been appointed Liaison Counsel in high profile cases in which significant recoveries for the shareholders were achieved. Below are some representative product liability cases that Gustafson Gluek is currently litigating:

Luis v. RBC Capital Markets, LLC (D. Minn.) Gustafson Gluek represents investors who were improperly sold high-risk reverse convertible notes. These investments triggered devastating financial losses for individuals with conservative investment goals.

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Ochoa et al. v. Pershing, LLC (N.D. Texas) Gustafson Gluek represents investors who were defrauded by Pershing, LLC as a result of Pershing’s role in facilitating and profiting from the R. Allen Stanford Ponzi scheme.

Walsh, et al., v. Buchholz, et al. (D. Minn.) Gustafson Gluek represents individuals who invested in a company that developed a novel dental anesthetic delivery system. Those individuals were defrauded when the officers and directors orchestrated a sale of the company that grossly diluted the investors’ financial interest in the company.

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Pro Bono & Community

At Gustafson Gluek PLLC, we recognize that those who provide legal services are in a unique position to assist others. We strongly believe in giving back to the community in which we are allowed to practice by providing legal services to those in need. The law can make an immense difference in an individual’s life; however, effectively navigating the legal system is not an easy task. Providing pro bono legal services promotes access to justice, by giving counsel to those who otherwise would not have it.

In keeping with this commitment to providing representation to those who otherwise do not have access to representation, Dan Gustafson was one of four lawyers who helped develop and implement the Minnesota Pro Se Project for the Minnesota Chapter of the Federal Bar Association. Because the Federal Bar Association did not have funding for the project, Gustafson Gluek volunteered to administer the Project during its inaugural year, starting in May 2009, devoting extensive resources to matching pro se litigants with volunteer counsel. In 2010, Chief Judge Michael Davis of the District of Minnesota awarded Dan Gustafson a Distinguished Pro Bono Service Award for “rising to the Court’s challenge of bringing the idea of the Pro Se Project to fruition and nurturing the Project into its current form.” Gustafson Gluek has continued representing clients through the Pro Se Project since that time.

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Gustafson Gluek Personnel Support the Following Volunteer Organizations

• American Antitrust Institute • American Bar Association • Animal Legal Defense Fund • Association of Legal Administrators • Cookie Cart • COSAL • Diverse Daisies • Division of Indian Work • Domestic Abuse Project • Federal Bar Association • Federal Pro Se Project • Hennepin County Bar Association • Infinity Project • Minnesota Paralegal Association • Minnesota State Bar Association • Minnesota Women Lawyers • MinnPost • MN Chapter of the Federal Bar Association • MN Urban Debate League • Page Education Foundation • Southern MN Regional Legal Services • The Fund For Legal Aid Society • University of Minnesota Mood Courts • University of St. Thomas Mentor • Externship Program • Volunteer Lawyers Network • With Purpose

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Our Professionals

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DANIEL E. GUSTAFSON

Daniel E. Gustafson is a founding member of Gustafson Gluek PLLC. Mr. Gustafson has dedicated his career to helping individuals or small businesses litigate against large corporation for various antitrust, product defect or consumer fraud violations. He has also strived to use his legal skills to represent those who cannot otherwise afford a lawyer. Mr. Gustafson served as a volunteer public defender in federal court, he was involved in helping develop the Federal Bar Association’s Pro Se Project, which coordinates volunteer representation for pro se litigants, and he has spent thousands of hours representing individuals on a pro bono basis. In 2019, he was given a lifetime achievement award by the Minnesota Federal Bar Association for his work on the Pro Se Project. Mr. Gustafson is admitted to practice in the United States District Court for the District of Minnesota, the United States District Court for the District of North Dakota, the United States District Court for the Eastern District of Michigan, the United States District Court for the Western District of Michigan, the United States District Court for the Eastern District of Wisconsin, the United States Courts of Appeals for the First, Third, Fifth, Sixth, Eighth and Eleventh Circuits, the Minnesota Supreme Court and in the United States Supreme Court.

Mr. Gustafson was an adjunct professor at the University of Minnesota Law School for many years, teaching a seminar long course on the “Fundamentals of Pretrial Litigation.”

Mr. Gustafson is a past president of the Federal Bar Association, Minnesota Chapter (2002-2003) and served in various capacities in the Federal Bar Association over the last several years. He was the Vice-Chair of the 2003 Eighth Circuit Judicial Conference held during July 2003 in Minneapolis (Judge Diana E.

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Murphy was the Chair of the Conference). He is a member of the Hennepin County, Minnesota, Federal, and American Bar Associations.

In September 2011, Mr. Gustafson testified before the At A Glance House Committee on the Education Judiciary, Subcommittee on • University of Minnesota Law School - J.D., cum laude (1989) Intellectual Property, • University of North Dakota - B.S., magna cum Competition and the Internet laude (1986) regarding the proposed merger

Court Admissions between Express Scripts and • Minnesota Medco. Mr. Gustafson also • U.S. District Court for the District of Minnesota • U.S. Court of Appeals for the First, Second, testified before the United States Third, Fifth, Sixth, Eighth, Tenth and Eleventh Congressional Commission on Circuits Antitrust Modernization in June • U.S. Supreme Court 2005. In addition to Recognition congressional testimonies, Mr. • Lifetime Achievement Award from the District of Minnesota Bar (2019) Gustafson has authored or • Selected as a Minnesota Super Lawyer by Super presented numerous seminars Lawyers in the field of antitrust litigation (2001 - and continuing legal education 2020) • Selected as an Attorney of the Year (2010, 2013, pieces on various topics related 2017) by Minnesota Lawyer to class action litigation, antitrust, • Ranked in the Top 100 Minnesota Lawyers by consumer protection or legal Super Lawyers (2012-2019) • Recognized as a North Star Lawyer by the advocacy. Minnesota State Bar Association (2012, 2013, 2015, 2018) Mr. Gustafson served as a law Received the American Antitrust Institute • clerk to the Honorable Diana E. Meritorious Service Award (2014) • Director of The Fund for Legal Aid Board Murphy, United States District (2014-2018) Judge for the District of • Infinity Project Board Member (2015) Minnesota (1989-91). Following • MWL President’s Leadership Circle (2013-2014) • UST School of Law Mentor (2014-2015) his judicial clerkship, Mr. • AAI Annual Private Enforcement Award and Gustafson worked in the fields of Conference committee member (2014- 2016) antitrust and consumer protection class action litigation. In May 2003, Mr. Gustafson

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formed Gustafson Gluek PLLC where he continues to practice antitrust and consumer protection class action law.

Mr. Gustafson has been named Lead or Co-Lead Counsel, Co-Lead Trial Counsel, or Settlement counsel in many cases over the years, including:

• In re Syngenta Litig. (Minn.)

• In re Broiler Chicken Antitrust Litig. (N. D. Ill)

• In re Surescripts Antitrust Litig. (N.D. Ill.)

• In re Medtronic, Inc. Sprint Fidelis Liability Litig. (D. Minn.)

• Precision Assocs. Inc. v. Panalpina World Transport (Holding) Ltd. (E.D.N.Y)

• In re Medtronic, Inc. Implantable Defibrillators Liability Litig. (D. Minn.)

• In re Vitamin C Antitrust Litig. (E.D.N.Y.)

• In re DRAM Antitrust Litig. (N.D. Cal.)

• The Shane Group, Inc. v. Blue Cross Blue Shield of Michigan (E.D. Mich.)

• Karsjens v. Jesson (D. Minn.)

• Synthes USA, LLC v. Spinal Kinetics (N.D. Cal.)

• KBA-Giori, North America, Inc., v. Muhlbauer, Inc. (E.D. Va.)

• Spine Solutions, Inc. v. Medtronic Sofamor Danek, Inc. (W.D. Tenn.)

• Dryer v. National Football League (D. Minn.)

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KAITLYN L. DENNIS

Kaitlyn L. Dennis joined Gustafson Gluek PLLC as an associate in 2016. Since joining the Firm, Ms. Dennis has been practicing in the areas of consumer protection, product liability and antitrust litigation.

In addition to her regular practice, Ms. Dennis has assisted multiple pro se litigants through the Federal Bar Association’s Pro Se Project and is recognized as a North Star Lawyer for providing at least 50 hours of pro bono legal services in a calendar year. She recently was the lead attorney in an arbitration trial alleging workplace discrimination on behalf of a pro bono client. In November 2019, she was a featured speaker at the American Antitrust Institute’s Young Lawyers Breakfast in Washington D.C. She is an active member of the American Bar Association, Federal Bar Association, Minnesota Bar Association, Minnesota Women Lawyers, and the Young Lawyers Division of the Committee to Support the Antitrust Laws (“COSAL”). Ms. Dennis is admitted to the Minnesota Bar and is admitted to practice in the United States District Court for the District of Minnesota.

Prior to joining Gustafson Gluek, Ms. Dennis worked as a fellowship attorney at the Equal Employment Opportunity Commission and assisted the Honorable Arthur J. Boylan, ret., during the mediation of the bankruptcy of the Archdiocese of St. Paul and Minneapolis.

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At A Glance Education • University of Minnesota Law School - J.D. (2015)

• Dean’s list at U of M Law School (2012–2015)

• Southwestern University - B.A. (2010)

• Managing Editor of the Minnesota Law Review

• Highest Grade (Book Award), Professional Responsibility: Civil Trial Law

Recognition • MSBA North Star Lawyer (2018-2019)

Speaking Engagements • American Antitrust Association, Young Lawyer’s Breakfast (November 12, 2019) • Minnesota Federal Bar Association, Pro Se Project and a Pint (January 10, 2019)

Ms. Dennis has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• Ehlis v. DAP Products, Inc. (D. Minn.)

• In re Interior Molded Doors Indirect Purchaser Antitrust Litig. (E.D. Va.)

• In re Equifax, Inc. Customer Data Security Breach Litig. (N.D. Ga.)

• FCA US LLC Monostable Electronic Gearshifts Litig. (E.D. Mich.)

• Kjessler v. Zaappaaz, Inc. et al. (S.D. Tex.)

• Fath v. American Honda Motor Co., Inc. (D. Minn.)

• In re Generic Pharmaceuticals Pricing Antitrust Litig. (E.D. Pa.)

• In re Automotive Parts Antitrust Litig. (E.D. Mich.)

• In re Volkswagen “Clean Diesel” Marketing Sales Practices, and Products Liability Litig. (N.D. Cal.)

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DAVID A. GOODWIN

David A. Goodwin is a member of Gustafson Gluek PLLC. When Mr. Goodwin joined the Firm in 2008, he began practicing in the areas of antitrust, securities and consumer protection. Since then, he has represented many small businesses and individuals in litigating their claims against some of the largest companies in the world.

In addition, Mr. Goodwin has served as counsel to many individuals on a pro bono basis through his work with the Minnesota Federal Court’s Pro Se Project, which matches pro se litigants with pro bono attorneys. Through the Pro Se Project, Mr. Goodwin has represented individuals in bringing employments claims, constitutional claims and other civil claims that might otherwise not have been heard.

Mr. Goodwin is admitted to practice in the Minnesota Bar and is admitted to practice in the United States District Court for the District of Minnesota.

Mr. Goodwin is active in the Federal Bar Association on the national level as well as with the Minnesota Chapter. He has served as a National Director of the FBA. He is also a past Chair of the Younger Lawyers Division. Currently, he is an Eight Circuit Vice President. David is also a Director of the Minnesota Chapter of the FBA, where he serves as the FBA Liaison for the Pro Se Project. Mr. Goodwin is also active with the Minnesota State Bar Association, where he has served as a Co-Chair of the Consumer Litigation Section.

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At A Glance Education • DePaul University College of Law - J.D. (2006)

• University of Wisconsin - B.A. (2001)

Recognition • Minnesota “Rising Star” (2013-2018)

• MSBA North Star Lawyer (2012-2016, 2018)

Mr. Goodwin has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• Krukas et al. v. AARP, Inc., et al. (D.D.C.) • Salmons v. National Railroad Passenger Corp., d/b/a AMTRAK (D.D.C.) • FCA US LLC Monostable Electronic Gearshifts Litig. (E.D. Mich.) • Krautkramer v. Yamaha Motor Corporation, USA (D. Minn.) • Reynolds, et al., v. FCA US, LLC (E.D. Mi.) • Gisairo v. Lenovo (United States) Inc. (D. Minn.) • Luis, et al., v. RBC Capital Markets, LLC (D. Minn.) • Kottemann Orthodontics, P.L.L.C. v. Delta Dental Plans Association, et al. (D. Minn.) • In re: Dealer Management Systems Antitrust Litig. (N.D. Ill.) • Karsjens et al. v. Jesson (D. Minn.) • In re: National Prescription OpPhillips v. Caliber Home Loans (D. Minn.) • Woronko v. General Motors, LLC (E.D. Mich.) • Dryer et al. v. Nat’l Football League (D. Minn.) • National Hockey League Players’ Concussion Injury Litig. (D. Minn.) • In re Aluminum Warehousing Antitrust Litig. (S.D.N.Y.)

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DANIEL C. HEDLUND

Daniel C. Hedlund is a member of Gustafson Gluek PLLC, having joined the Firm in 2006. Throughout his legal career, Mr. Hedlund has practiced in the areas of antitrust, securities fraud, and consumer protection, and, in 2021, Mr. Hedlund was appointed to Co-Chair the Firm’s antitrust litigation team.

Mr. Hedlund is admitted to practice in the United States District Court for the District of Minnesota, the Eighth Circuit Court of Appeals, the Second Circuit Court of Appeals, and in Minnesota State Court. He is a member of the Federal, American, Minnesota, and Hennepin County Bar associations. Mr. Hedlund is active in the Minnesota Chapter of the Federal Bar Association (FBA), currently serving as Co-Vice President for the Eighth Circuit. He has previously served in several roles for the Minnesota Chapter including: Co- Vice President, Legal Education; Co-Vice President, Special Events; Co-Vice President, Monthly Meetings; Secretary; and Liaison between the FBA and the Minnesota State Bar Association. He recently served as Chairman for the Antitrust Section of the Minnesota State Bar Association (MSBA), Secretary for the MSBA Consumer Litigation Section, and is past President of the Committee to Support Antitrust Laws.

In addition to presenting at numerous CLEs, Mr. Hedlund has testified multiple times before the Minnesota legislature on competition law, and before the Federal Rules Committee. He is a co-author of the “Plaintiff Overview” in Private Antitrust Litigation 2015 – Getting the Deal Through, and a contributor to Concurrent Antitrust Criminal and Civil Procedure 2013 – American Bar Association.

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In 2013-2020, he has been At A Glance designated as a Minnesota Education “Super Lawyer,” in the field of • University of Minnesota Law School - J.D., cum antitrust law. He was also laude (1995) ranked in the Top 100 • Note and Comment Editor, member of Minnesota Lawyers by Super Minnesota Journal of Global Trade (1993-1995) Lawyers in 2015 and • Carleton College - B.A. (1989) 2017-2020. Mr. Hedlund has Recognition served as a volunteer • Minnesota “Super Lawyer” (2013-2020) attorney for the Minnesota • Top 100 MN “Super Lawyer” (2015, 2017-2020) Federal Bar Association’s • Minnesota District Court’s Distinguished Pro Federal Pro Se Project and is Bono Service Award (2011) the recipient of the • Recipient of the Federal Bar Association’s Minnesota District Court’s John T. Stewart, Jr. Memorial Fund Writing Distinguished Pro Bono Award (1994) Service Award in 2011. Publications • Co-Authored “Plaintiff Overview” in Private Mr. Hedlund served as a law Antitrust Litigation 2015 – Getting the Deal Through clerk on the Minnesota Court of Appeals (1997) and in the • Contributor to Concurrent Antitrust Criminal and Civil Procedure 2013 – American Bar Fourth Judicial District of Association Minnesota (1995-1996).

Mr. Hedlund has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re Broiler Chicken Antitrust Litig. (N.D. Ill.) • In re Interior Molded Doors Indirect Purchaser Antitrust Litig. (E.D. Va.) • In re Pork Antitrust Litig. (D. Minn.) • Bhatia v. 3M Co. (D. Minn.) • In re Dealer Management Systems Antitrust Litig. (N.D. Ill.) • Kleen Prods. v. Intl. Paper (Containerboard Antitrust Litig.) (N.D. Ill.)

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• In re CenturyLink Sales Practices and Securities Litig. (D. Minn.) • Precision Assocs., Inc. v. Panalpina World Transport (Holding) Ltd. (E.D.N.Y.) • The Shane Group, Inc. v. Blue Cross Blue Shield of Michigan (E.D. Mich.) • In re Vitamin C Antitrust Litig. (E.D.N.Y.) • In re Blue Cross Blue Shield Antitrust Litig. (N.D. Ala.) • In re DRAM Antitrust Litig.

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JASON S. KILENE

Jason Kilene is a member of Gustafson Gluek PLLC. He is a graduate of the University of North Dakota (B.A. 1991) and a graduate of the University of North Dakota School of Law (J.D., with distinction, 1994).

Mr. Kilene joined Gustafson Gluek in 2003 and became a member shortly thereafter. Prior to joining Gustafson Gluek, Jason served as a law clerk to the Honorable Bruce M. Van Sickle, United States District Judge for the District of North Dakota. Following his clerkship, Mr. Kilene represented numerous clients in the areas of commercial and complex litigation. Since then, Jason has continued his practice in the areas of antitrust, consumer protection and other complex litigation.

Mr. Kilene is admitted to the Minnesota Bar, North Dakota Bar and is admitted to practice in the United States District Court for the District of Minnesota and the District of North Dakota. He is also a member of the Hennepin County, Minnesota, North Dakota, and Federal Bar Associations.

Mr. Kilene currently represents individuals and businesses harmed by anticompetitive business practices. He was part of the trial team that successfully recovered damages suffered by his clients due to alleged defective software in In re J.D. Edwards World Solutions Company, (AAA) (trial counsel for plaintiffs Quantegy and Amherst). Mr. Kilene also plays a significant role in identification, investigation, initiation and development of complex class action matters, along with his significant involvement with client relations.

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At A Glance Education • University of North Dakota School of Law - J.D., with distinction (1994) • University of North Dakota - B.A. (1991)

Court Admissions • Minnesota State Bar • North Dakota State Bar • U.S. District Court for the District of Minnesota • U.S. District Court for the District of North Dakota

Mr. Kilene has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re Automotive Parts Antitrust Litig. (E.D. Mich.)

• In re Transpacific Passenger Air Transportation Antitrust Litig. (N.D. Cal.)

• In re Domestic Drywall Antitrust Litig. (E.D. Pa.)

• In re Payment Card Interchange Fee and Merchant Discount Litig. (E.D.N.Y.)

• In re Broiler Chicken Antitrust Litig. (N.D. Ill.)

• In re Domestic Drywall Antitrust Litig. (E.D. Penn.)

• In re Lithium Ion Batteries Antitrust Litig. (N.D. Cal.)

• In re Optical Disk Drive Antitrust Litig. (N.D. Cal.)

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MICHELLE J. LOOBY

Michelle J. Looby is a member of Gustafson Gluek PLLC. Ms. Looby joined Gustafson Gluek in 2008 and became a member in 2015. She has recently been named as Co-Chair of the Firm’s antitrust litigation team.

In the courtroom, Ms. Looby has served in leadership roles in numerous class actions. Outside the courtroom, Ms. Looby is actively involved in the legal community serving on the Advisory Board of the American Antitrust Institute, as the Secretary and Diversity Liaison for the Minnesota State Bar

Association’s Antitrust Council, At A Glance and on the executive Education committee of the Coalition in • William Mitchell College of Law - J.D., magna cum laude(2007) Support of the Antitrust Laws. In

• Member of the William Mitchell Law Review addition, she is actively involved (2005-2007) in the American Bar Association, • Assistant Editor of the William Mitchell Law Federal Bar Association, and Review (2006-2007) Minnesota Women Lawyers, • Recipient of the CALI Excellence for the Future previously having served on its Award Board of Directors. Ms. Looby • University of Minnesota - B.A., with distinction (2004) also served on Law360’s Competition Editorial Advisory Recognition • Minnesota “Rising Star” 2014-2019 Board, a leading daily legal news and intelligence service • AAI Award for Outstanding Antitrust Litigation Achievement by a Young Lawyer – 2015 that reaches over one million

Publications recipients each day. • Co-Authored Plaintiff Overview Chapter of Ms. Looby is admitted to the Getting the Deal Through: Private Antitrust Litigation 2015 Minnesota Bar and is admitted to practice in the United States

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District Court for the District of Minnesota and the United State District Court for the District of North Dakota.

Ms. Looby has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re Interior Molded Doors Antitrust Litig. (E.D.V.A.)

• In re DPP Beef Litigation (D. Minn.)

• In re Dealer Management Systems Antitrust Litig. (N.D. Ill.)

• Precision Associates, Inc. et al. v. Panalpina World Transport (Holding), Ltd., et al. (E.D.N.Y.)

• Powell Prescription Center, et al. v. Surescripts, LLC et al. (N.D. Ill.)

• In re CenturyLink Residential Customer Billing Disputes Litig. (D. Minn.)

• In re Allura Fiber Cement Siding Products Liability Litig. (D.S.C.)

• In re Broiler Chicken Antitrust Litig. (N.D. Ill.)

• In re Pork Antitrust Litig. (D. Minn.) • In re Generic Pharmaceuticals Pricing Antitrust Litig. (E.D. Pa.)

• In re Automotive Parts Antitrust Litig. (E.D. Mich.)

• In re Opana ER Antitrust Litig. (N.D. Ill.)

• In re Restatsis (Cyclosporine Opthalmic Emulsion) Antitrust Litig. (E.D.N.Y)

• In re Asacol Antitrust Litig. (D. Mass.)

• In re Celebrex (Celecoxib) Antitrust Litig. (E.D. Va.)

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MARY NIKOLAI Mary Nikolai joined Gustafson Gluek PLLC as an associate in 2019, after clerking for the Honorable Luis Bartolomei, District Judge, Fourth Judicial District of Minnesota. Since joining the Firm, Ms. Nikolai has represented individuals and classes in asserting various consumer fraud and product defect claims. She has also represented a number of former members of the nationwide FLSA collective alleging off-the-clock work in arbitrations throughout the country. Ms. Nikolai is admitted to the Minnesota State Bar and the United States District Court for the District of Minnesota. She is also an active member of the Federal Bar Association and the Minnesota Women’s Lawyers.

During law school, Ms. Nikolai clerked for two Twin Cities law firms and was a judicial extern for the Honorable Patrick Schiltz. She was also a Certified Student Attorney at the St. Thomas Interprofessional Center for Counseling and Legal Services, where she represented a family seeking asylum in the United States, as well as individuals at detained master calendar and bond hearings.

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At A Glance Education • University of St. Thomas School of Law - J.D. (2018) • DePaul University - B.A. (2012) • Selected as the University of St. Thomas Clinic Student of the Year (2017-2018)

Ms. Nikolai has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• Turner et al v. Chipotle Mexican Grill, Inc. (D. Colo.) • Reitman v. Champion Petfoods (C.D. Cal.) • Weaver v. Champion Petfoods (E.D. Wis.) • In re Big Heart Pet Brands Litig. (N.D. Cal.) • Krukas et al. v. AARP, Inc., et al. (D.D.C.) • Bhatia v. 3M Co. (D. Minn.) • Doe v. Hanson et al. (Minn.) • Hudock v. LG Electronics USA, Inc. (D. Minn.) • Brewster v. United States (D. Minn.)

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BRITTANY RESCH

Brittany Resch joined Gustafson Gluek as an associate in June 2016, after clerking for the Honorable Richard H. Kyle, Senior United States District Judge, District of Minnesota. Since joining the firm, Ms. Resch has been practicing primarily in the area of antitrust litigation. She represents small business and individuals in pursue these claims, often against some of the largest corporations in the world, and in courts across the country.

In addition to her antitrust practice, Ms. Resch also spends a great deal of time on pro bono matters. Ms. Resch and her co-counsel were recently named Attorneys of the Year by Minnesota Lawyer for their work successfully helping a pro se litigant navigate the federal courts via the Federal Bar Association’s Pro Se Project. She has also worked with the Volunteer Lawyer Network’s Letters to Creditors Program, assisting low-income persons protect their rights.

Ms. Resch is an active member of the Minnesota Federal Bar Association, where she serves on the Community Outreach/Court camp Committee as well as the Membership Committee. She also is a member of the Minnesota Women Lawyers, in which she serves on the Partner Leadership Council.

During law School, Ms. Resch was a law clerk for the United States Attorney’s Office and Hennepin County Attorney’s Office. She also provided representation to low-income persons with consumer protection issues as a certified student attorney and served as a judicial extern for the Honorable Steven E. Rau, Magistrate Judge, District of Minnesota. After graduating from law school, Ms. Resch served as a law clerk to the Honorable Richard H. Kyle, Senior United States District Judge, District of Minnesota.

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At A Glance Education • University of Minnesota Law School - J.D. (2015)

• Participant in the Phillip C. Jessup International Moot Court Competition Team

• Served on the Board of NOLA MN

• Served on the Board of the Federal Bar Associations University of Minnesota Law School Chapter

• University of Minnesota - B.A., magna cum laude (2012)

Recognition • Minnesota “Rising Star”( 2020)

• Minnesota Lawyer’s Attorneys of the Year (2019)

Ms. Resch has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re Broiler Chicken Antitrust Litig., (N.D. Ill.)

• In re Pork Antitrust Litig. (D. Minn.)

• In re Disposable Contact Lens Antitrust Litig. (M.D. Fla.)

• Hudock & Villa Lara v. LG Electronics USA, Inc. & Best Buy Co., Inc. (D. Minn.)

• In re Asacol Antitrust Litig. (D. Mass.)

• In re Automotive Parts Antitrust Litig. (E.D. Mich.)

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JOSHUA J. RISSMAN

Joshua Rissman joined Gustafson Gluek in 2010 as an associate and became a member of the Firm in 2018. Since joining the Firm, Mr. Rissman has focused his practice on antitrust and class action litigation. Mr. Rissman prides himself on vigorously representing small businesses and individuals damaged by wrongful corporate and government conduct.

In addition to his antitrust class action practice, Mr. Rissman has brought several pieces of important constitutional litigation involving mistreatment of juvenile detainees and police brutality. He currently represents a former juvenile detainee who alleges he was abused at the Minnesota Correctional Facility – Red Wing, and that the administration was aware of the risks to the juvenile and failed to protect him. Doe v. Hanson et al. (Minn.) Mr. Rissman was also the lead attorney in a section 1983 constitutional rights action brought on behalf of the family of a man killed by Brooklyn Center police officers in 2015. Khottavongsa v. City of Brooklyn Center (D. Minn.). Mr. Rissman is also representing a class of protestors who were unlawfully subjected to tear gas and pepper spray in the protest following the George Floyd protest. Samaha, et al. v. City of Minneapolis, et al (D. Minn.).

Joshua was selected a Minnesota Rising Star by Super Lawyers in the area of antitrust litigation (2014 – 2018). He is the Treasurer of the Antitrust Section of the Federal Bar Association, and counsel member of the Minnesota Bar Association Antitrust Section. Joshua also participates in the Pro Se Project, representing civil litigants in federal court who would otherwise go without representation.

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At A Glance Education • University of Minnesota Law School - J.D., cum laude (2010)

• University of Minnesota - B.A., magna cum laude (2005)

Recognition • Minnesota “Rising Star” 2014-2018

Mr. Rissman has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re DPP Beef Antitrust Litig. (D. Minn.) • In re Containerboard Antitrust Litig. (N.D. Ill.) • In re Broiler Chicken Antitrust Litig. (N.D. Ill.) • In National Hockey League Players’ Concussion Injury Litig. (D. Minn.) • Precision Assocs., Inc. v. Panalpina World Transport (Holding) Ltd. (E.D.N.Y.) • In re Lithium Batteries Antitrust Litig. (N.D. Cal.) • In re Optical Disk Drives Litig. (N.D. Cal.) • In re Asacol Antitrust Litig. (D. Mass.) • In re Opana Antitrust Litig. (N.D. Ill.) • City of Wyoming et al. v. Procter & Gamble Company et al. (D. Minn.)

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MICKEY STEVENS

Mickey Stevens joined Gustafson Gluek PLLC as an associate in 2018, after clerking for the Honorable Joseph Klein, District Judge, Fourth Judicial District of Minnesota. Since joining the Firm, Mr. Steven’s has represented individuals and classes in cases alleging antitrust conspiracies, illegal kickback schemes and constitutional violations.

Mr. Stevens is an active member of the Federal Bar Association and the National LGBT Bar Association. He is passionate about using his legal education to help those in need overcome barriers to justice, by representing pro se litigants through the Federal Bar Association’s Pro Se Project and those referred to Gustafson Gluek by other sources. He is admitted to the Minnesota State Bar and the United States District Court for the District of Minnesota.

During law school, Mr. Stevens served as a judicial extern for the Honorable Patrick J. Schiltz, U.S. District Court Judge for the District of Minnesota. He was also a Student Instructor for the Legal Research and Writing course and served on the boards of the Asylum Law Project, the Federal Bar Association’s University of Minnesota Law School chapter, and the Student Intellectual Property Law Association.

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At A Glance Education

• University of Minnesota Law School - J.D. (2016) • Note and Comment Editor for the Minnesota Journal of Law, Science & Technology • Student Instructor for the Legal Research and Writing course • University of Wisconsin – Madison - B.A. (2013)

Mr. Stevens has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re Interior Molded Doors Indirect Purchaser Antitrust Litig. (E.D. Va.) • In re Dealer Management Systems Antitrust Litig. (N.D. Ill.) • Vallarta v. United Airlines, Inc. (N.D. Cal.) • O’Kane v. JetBlue Airways Corp. (S.D.N.Y.) • Shattenkirk v. Alaska Airlines, Inc. (W.D. Wash.) • Salmons v. National Railroad Passenger Corp. (D.D.C.) • Doe v. State of Minnesota, et al. (Minn. Dist. Ct.)

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LING S. WANG

Ling S. Wang joined Gustafson Gluek PLLC as an associate in 2017, after clerking at the Firm throughout her years in law school.

Since joining the Firm as an associate, Ms. Wang has been practicing in the areas of antitrust, consumer protection and product liability litigation. She speaks English and Fuzhouhua, and has basic language skills in Mandarin Chinese. Ms. Wang draws on her education, knowledge of multiple industries, and experience to advocate for a diverse array of clients. In addition to her regular practice, Ms. Wang has taken on several pro bono cases. Her pro bono practice includes representing individuals in need through the FBA’s Pro Se Project and Volunteer Lawyers Network. Ms. Wang is a member of the Federal Bar Association, Minnesota Women Lawyers, and Minnesota Asian Pacific American Bar Association. As part of her volunteer work, she has been recognized as a North Star Lawyer by the Minnesota State Bar Association (2018-2019) for providing legal services to those who otherwise could not afford representation. Ms. Wang is admitted to the Minnesota State Bar and the U.S. District Court for the District of Minnesota. During law school, Ms. Wang externed with a law firm in Edina. For two years, she provided representation to low-income persons with immigration issues as a certified student attorney with the University’s Interprofessional Center for Counseling and Legal Services. Ms. Wang also completed a mentor externship program with the Honorable Steven E. Rau, Magistrate Judge, District of Minnesota and served as a judicial extern for the Honorable Mary R. Vasaly, District Judge, Fourth Judicial District of Minnesota.

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At A Glance Education • St. Thomas School of Law - J.D. (2017)

• Research Assistant, St. Thomas School of Law

• Member of St. Thomas Law Journal

• Augsburg University - B.A. (2013)

Recognition • Minnesota “Rising Star” (2018-2019)

• MSBA North Star Lawyer (2020)

Ms. Wang has been actively involved in several cases in which Gustafson Gluek is or had been appointed to leadership positions or actively involved including:

• In re Broiler Chicken Antitrust Litig. (N.D. Ill.)

• In re: Remicade Antitrust Litig. (E.D. Pa.)

• In re: CenturyLink Sales Practices and Securities Litig. (D. Minn.)

• Hall v. State of Minn. (Minn. Dist. Ct.)

• In re: Generic Pharmaceutical Pricing Antitrust Litig. (E.D. Pa.)

• In re: Payment Card Interchange Fee and Merchant Discount Antitrust Litig. (E.D.N.Y.)

• In re: Restasis (Cyclosporine Ophthalmic Emulsion) Antitrust Litig. (E.D.N.Y.)

gustafsongluek.com Gustafson Gluek PLLC. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 63 of 228 PageID# 11258

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation Firm Name: Gustafson Gluek PLLC Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Gustafson, Daniel E. P 2.70 $1,050.00 $2,835.00 Gustafson, Daniel E. P 0.90 $1,075.00 $967.50 Gustafson, Daniel E. P 3.70 $1,100.00 $4,070.00 Hedlund, Daniel C. P 35.60 $875.00 $31,150.00 Hedlund, Daniel C. P 198.40 $900.00 $178,560.00 Hedlund, Daniel C. P 385.10 $925.00 $356,217.50 Kilene, Jason S. P 74.20 $875.00 $64,925.00 Kilene, Jason S. P 50.20 $900.00 $45,180.00 Kilene, Jason S. P 1.70 $925.00 $1,572.50 Goodwin, David A. P 0.50 $625.00 $312.50 Looby, Michelle J. P 84.40 $625.00 $52,750.00 Looby, Michelle J. P 716.10 $650.00 $465,465.00 Looby, Michelle J. P 670.70 $675.00 $452,722.50 Rissman, Joshua J. P 1.80 $500.00 $900.00 Borrelli, Raina C. P 1.40 $500.00 $700.00 Dennis, Kaitlyn L. A 36.00 $375.00 $13,500.00 Dennis, Kaitlyn L. A 660.10 $400.00 $264,040.00 Dennis, Kaitlyn L. A 730.50 $425.00 $310,462.50 Dennis, Kaitlyn L. A 84.00 $500.00 $42,000.00 Brittany N. Resch A 17.20 $425.00 $7,310.00 Stevens, Mickey L. A 318.90 $350.00 $111,615.00 Stevens, Mickey L. A 105.60 $375.00 $39,600.00 Wang, Ling S. A 7.00 $350.00 $2,450.00 Nikolai, Mary M. A 11.90 $325.00 $3,867.50 Mundahl, Danette K. PL 6.00 $150.00 $900.00 Moen, Sarah A. PL 5.50 $225.00 $1,237.50 Holzer, Jamie L. PL 86.70 $200.00 $17,340.00 Noble, Chelsea M. PL 7.40 $150.00 $1,110.00 Jakubauskiene, Diana PL 3.00 $200.00 $600.00 Francis M. Mosedale LC 8.50 $250.00 $2,125.00

TOTALS 4315.70 $2,476,485.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 64 of 228 PageID# 11259

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Gustafson Gluek PLLC Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $5,030.57 Filing / Misc. Fees $300.00 Overnight Delivery/Messengers $96.00 Photocopying $1,562.50 Postage $0.00 Service of Process Fees $202.35 Telephone / Fax $442.81 Transportation / Meals / Lodging $24,518.37 Litigation Fund Contributions $612,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $644,152.60 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 65 of 228 PageID# 11260

Exhibit A-2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 66 of 228 PageID# 11261

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF WILLIAM V. REISS IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, William V. Reiss, hereby declare as follows:

1. I am a duly licensed attorney in New York and am admitted pro hac vice in this

Court. I am a partner at Robins Kaplan LLP. On December 26, 2018, the Court appointed me as

one of Interim Co-Lead Counsel in the above-captioned action (“Action”), and on February 5,

2021, my firm was appointed Settlement Class Counsel along with Gustafson Gluek PLLC and

The Joseph Saveri Law Firm. I submit this declaration in support of Indirect Purchaser Plaintiffs’

Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the

Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has served as Interim Co-Lead Counsel and Settlement Class Counsel for

the Indirect Purchaser Plaintiffs in this litigation on an entirely contingent basis. The background

and experience of Robins Kaplan LLP and its attorneys are summarized in the firm resume

attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’ Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 67 of 228 PageID# 11262

fee lodestar in this litigation. This includes work performed by my firm’s attorneys and

professional staff, computed at my firm’s historical hourly rates from inception through February

28, 2021.

5. The total number of hours expended in this litigation by my firm from inception

through February 28, 2021 is 6,099.0. The total lodestar for my firm is $3,404,412.00. The total

attorney and professional staff time reflected in this declaration is based on my firm’s

contemporaneous, daily time records regularly prepared and maintained by my firm, as well as

any reductions applied to avoid duplication and ensure efficiency.

6. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $668,741.85 in

unreimbursed costs and expenses in this litigation from inception through March 31, 2021,

including $612,000 in contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My

firm advanced these costs and expenses with no assurance that such costs and expenses would be

repaid.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 68 of 228 PageID# 11263

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 3rd day of May, 2021, in New York, New York.

William V. Reiss ROBINS KAPLAN LLP

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 69 of 228 PageID# 11264

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 70 of 228 PageID# 11265

BISMARCK BOSTON LOS ANGELES MINNEAPOLIS NEW YORK SILICON VALLEY SIOUX FALLS

ANTITRUST LITIGATION EXPERIENCE

ROBINSKAPLAN.COM

1 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 71 of 228 PageID# 11266

TABLE OF CONTENTS

WHO WE ARE: ROBINS KAPLAN 1

DIVERSITY 2

TRIAL VICTORIES 3

TRIAL EXPERIENCE RECOGNITION 4

WHO WE ARE: ANTITRUST AND TRADE REGULATION GROUP 5

ANTITRUST LITIGATION SUCCESS 6

COURT-APPOINTED LEADERSHIP IN ANTITRUST CASES 8

ANTITRUST RECOGNITION 10

THE ROBINS KAPLAN TEAM 13

2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 72 of 228 PageID# 11267

WHO WE ARE: ROBINS KAPLAN A national firm dedicated to trial work.

Robins Kaplan is among the nation’s premier trial law firms, with more than 250 attorneys across seven U.S. cities.

With one of the nation’s top-ranked antitrust practices, we are one of few national firms to have obtained landmark successes on behalf of both plaintiffs and defendants in major antitrust litigation and at trial, including in several of the most significant antitrust cases ever litigated.

We have secured nearly $10 billion in recoveries for antitrust plaintiffs in the past several years, recovering more than $2 billion for clients through jury verdicts alone.

Our lawyers secured the first settlement between a state and Big Tobacco using an antitrust theory, and we have forced critical structural reforms in many other industries. Our broad range of experience is reflected in the diverse backgrounds of our legal professionals.

Our persistent trial focus and readiness drives our success in and out of the courtroom.

11 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 73 of 228 PageID# 11268

DIVERSITY

Inclusion has been at the heart of our mission from the start. Robins Kaplan was founded by two Jewish lawyers who were excluded from other firms. They responded by creating a firm where all lawyers are welcome.

of associates hired in 2019 47% were attorneys of color.

of attorneys promoted to partner in 2020 are 50% from historically underrepresented groups.

of associates hired in 2019 53% were women.

SELECTED WORK: » Operate an attorney-led diversity committee founded over 20 years ago.

» Published groundbreaking Transgender Inclusion Guidebook for firm employees.

» Achieved Mansfield 3.0 Certification for 2020.

» Operate LEAD program that holds firm leadership accountable for diversity initiatives.

SELECTED RECOGNITION: » Leadership Council on Legal Diversity: Top Performer (2020).

» Named a best law firm for LGBTQ Individuals by Vault (2020).

» ABA Law Practice Division: Martha Fay Africa Golden Hammer Award (2019).

» National LGBT Bar Association: Best LGBTQ+ Lawyers Under 40 (2019).

» Leadership Council on Legal Diversity: Compass Award (2018).

» Minnesota Lawyer: Diversity & Inclusion Award (2018).

» Profiles in Diversity Journal: Diversity Leader (2017-19); Innovations in Diversity & Inclusion Award of Excellence (2017); Women Worth Watching (2011-20).

» Chambers USA: Diversity Award for Most Inclusive Firm for LGBT Lawyers (2016).

» The National Law Journal: Outstanding Women Lawyers (2015).

» Human Rights Campaign: 100% score in the Corporate Equality Index for LGBTQ-friendly work policies and practices (2009-21).

2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 74 of 228 PageID# 11269

TRIAL VICTORIES

Our trial lawyers have secured billions of dollars in damages in jury and arbitration awards against opponents from Apple to Disney to Starbucks.

$6.8 BILLION $2.7 BILLION

Settlement with Big Tobacco after a Arbitration award for a Kraft Foods spinoff historic 15-week trial. With the result, in breach of contract action against Robins Kaplan became “the vanguard Starbucks, which had terminated Kraft’s firm in the first successful battle with Big exclusive rights to sell Starbucks coffee in Tobacco” for states and health insurers grocery and retail stores. (Law360). Domino-like settlements with 45 states followed. Kraft Foods Global, Inc. v. Starbucks Corporation (S.D.N.Y.) State of Minnesota and Blue Cross & Blue Shield of Minnesota v. Philip Morris Inc., et al. (Minn.)

$520 MILLION $320 MILLION

Jury verdict against Microsoft for infringing Federal jury verdict, plus prejudgment a patent for web browser technology. interest, against the creators of “Who The Federal Circuit affirmed the award, Wants to Be a Millionaire?” in a dispute which increased to $565 million with pre- over the show’s profits. judgment interest. The case settled days before a second trial on invalidity. Celador International, Ltd. v. American Broadcasting Cos., Inc., et al. (C.D. Cal.), Eolas Technologies, Inc., et al. v. Microsoft aff’d (9th Cir.) Corp. (N.D. Ill.)

33 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 75 of 228 PageID# 11270

RECENT TRIAL EXPERIENCE RECOGNITION

“Elite Trial Lawyers List” “Plaintiffs’ Hot List”

“A-List”

“Client Service “Honor Roll: Most “Litigation Outlook: A-Team” Feared Law Firms” Awesome Opponent”

“Top 10 Plaintiffs Firm”

“Go-To Law Firms at the Top 500 Companies”

44 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 76 of 228 PageID# 11271 WHO WE ARE: ANTITRUST AND TRADE REGULATION GROUP

We are 36 attorneys and financial and economic experts who pursue industry- disrupting antitrust litigation. Most of the attorneys in our group have earned individual recognition for excellence in antitrust work. Highlights include:

MEEGAN HOLLYWOOD Global Competition Review 40 Under 40 | American Antitrust Institute Outstanding Antitrust Litigation Achievement by a Young Lawyer | American Bar Association On the Rise: Top 40 Young Lawyers | Global Competition Review Lawyer of the Year Under 40 Shortlist

KELLIE LERNER New York Law Journal Antitrust Trailblazer | Chambers USA: Antitrust New York: Band 1 | The Legal 500: Class Action-Antitrust | New York Law Journal Competition Lawyer Under 40 | New York Law Journal Distinguished Leader

WILLIAM V. REISS American Antitrust Institute Outstanding Antitrust Litigation Achievement by a Young Lawyer | The National Law Journal Antitrust Trailblazer | Law360 Competition Rising Star

AARON M. SHEANIN “Top Antitrust Lawyer” by the Daily Journal | “California Super Lawyer” by Super Lawyers | Finalist for “Consumer Attorney of the Year,” Consumer Attorneys of California

K. CRAIG WILDFANG Law360 Titan of the Plaintiff’s Bar| American Antitrust Institute Antitrust Enforcement Award / Outstanding Antitrust Achievement in Private Law Practice | Chambers USA: Antitrust Minnesota: Band 1 and Nationwide: Band 2 | The National Law Journal Antitrust Trailblazer

OUR TEAM » Two former U.S. Attorneys. INCLUDES: » Former special counsel for the DOJ Antitrust Division. » Former chair of Am Law 100 antitrust practice. » Former Dean and current President of the International Academy of Trial Lawyers.

5 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 77 of 228 PageID# 11272

ANTITRUST LITIGATION SUCCESS

Robins Kaplan has a well-established history of successfully leading major antitrust actions.

FOR PLAINTIFFS

Payment Card Automotive Parts Cathode Ray Tube Interchange Fee and Antitrust Litigation Antitrust Litigation Merchant Discount Antitrust Litigation $1.2 BILLION $300 MILLION TO DATE IN SETTLEMENT + $5.54 BILLION $22.5 MILLION JURY VERDICT In an unprecedented For a class of 10 million MDL stemming from the merchants, Robins Kaplan largest criminal antitrust Robins Kaplan represented pursued an innovative investigation in U.S. Best Buy in an action theory that Visa’s and history, Robins Kaplan alleging a conspiracy to fix Mastercard’s interchange has recovered more than the prices of cathode ray fee structure and rules $1.2 billion in settlements tubes, which were once are anticompetitive. The for purchasers of price- integral components of $5.54 billion settlement, fixed auto parts. The televisions and computer which was granted final cumulative figure is the monitors. The case approval, is the largest largest indirect purchaser concluded with settlements known settlement of a recovery in U.S. history. exceeding $300 million and private antitrust action in a $22.5 million jury verdict the 120-year history of the In re Automotive Parts against one defendant. Sherman Act. Antitrust Litigation (E.D. Mich.) In re Cathode Ray Tube In re Payment Card Antitrust Litigation Interchange Fee and (N.D. Cal.) Merchant Discount Antitrust Litigation Kirk Dahl, et al. v. Bain Capital Partners, LLC (E.D.N.Y.) Vitamins Antitrust Litigation $600 MILLION Air Cargo Shipping Services Antitrust $250 MILLION Litigation Robins Kaplan identified private equity firms’ The firm represented alleged conspiracy to $1.2 BILLION agribusiness clients suppress acquisition prices as opt-out plaintiffs for target companies in in litigation over a In a class action against leveraged buyouts and decade-long price- providers of air cargo recovered nearly $600 fixing conspiracy among services, Robins Kaplan million in settlements. collected evidence around international vitamin the world and compelled Kirk Dahl, et al. v. Bain manufacturers. The cases deposition testimony Capital Partners, LLC et al. settled before trial. through The Hague. The (D. Mass.) In re Vitamins Antitrust final two of 28 settlements Litigation (D.D.C.) came on the eve of trial.

In re Air Cargo Shipping Services Antitrust Litigation (E.D.N.Y.) 6 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 78 of 228 PageID# 11273

ANTITRUST LITIGATION SUCCESS CONTINUED

FOR DEFENDANTS

Wholesale Grocery Insulate SB, Inc. Omnicare, Inc. v. Products Antitrust v. Advanced Finishing Unitedhealth Group, Inc. Litigation Systems, Inc. Represented defendants Robins Kaplan LLP Robins Kaplan obtained Unitedhealth Group, served as lead counsel a Rule 12(b)(6)/Twombly Inc. and Pacificare, Inc. representing grocery dismissal of a putative in an antitrust lawsuit wholesaler Supervalu Inc. nationwide antitrust class involving alleged price- in consolidated federal action against Graco fixing and fraud related antitrust actions on behalf Inc. and its distributors to prescription drug of putative multi-state of spray foam insulation reimbursement under class of grocery retailers equipment, which had the federal Medicare challenging 2003 asset been brought after a Part D program. Plaintiff exchange transaction, and Federal Trade Commission Omnicare sought damages in a related Federal Trade decree related to Graco’s exceeding $1 billion and Commission investigation spray foam business permanent injunctive relief. regarding the asset acquisitions. Robins After summary judgment exchange transaction. Kaplan represented Graco motion was argued in Robins Kaplan persuaded on appeal, and it obtained August 2008, the U.S. the FTC to close its an affirmance by the District Court granted investigation without Eighth Circuit. summary judgment to action, and it obtained a defendants on all claims in Insulate SB, Inc. v. ruling excluding plaintiff’s January 2009 which the Advanced Finishing economics expert and Seventh Circuit affirmed Products & Equipment, granting summary on appeal. et al. (D. Minn.) judgment and an Eighth Omnicare, Inc. V. Circuit affirmance of Unitedhealth Group judgment in Supervalu’s In re Union Oil (N.D. Ill. 2009) favor in December 2019. Company of California In re Wholesale Grocery Products Antitrust In another case at the In re Farmed Salmon Litigation (D. Minn.) intersection between Antitrust Litigation antitrust and patent law, Robins Kaplan defended Digital Sun v. Section 5 antitrust Defended Norwegian farmed The Toro Co. allegations by the Federal salmon producer in series of Trade Commission against lawsuits alleging price-fixing UNOCAL based on in the market for farmed Robins Kaplan secured standard-setting theory Atlantic salmon. Obtained Rule 12 dismissal of a for reformulated gasoline voluntary dismissal of all complaint against The patents. claims in 2019. Toro Company by a manufacturer of smart- In re Union Oil Company of In re Farmed Salmon sprinkler technology, in a California (Federal Trade Antitrust Litig. (S.D. Fla.) case at the intersection Commission, 2004) between antitrust and patent law.

Digital Sun v. The Toro Company (N.D. Cal.) 7 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 79 of 228 PageID# 11274

COURT-APPOINTED LEADERSHIP IN ANTITRUST CASES

Sterk, et al. v. The Bank of Nova Scotia, et al., (D.N.J.)

In re Hard Disk Drives Suspension Assemblies Antitrust Litigation (N.D. Cal.)

In re Brand Name Prescription Drug Indirect Purchaser Antitrust Litigation (multistate)*

Ace Marine Rigging & Supply, Inc. v. Virginia Harbor Services, et al. (C.D. Cal.)*

In re Abbott Labs Norvir Antitrust Litigation (N.D. Cal.)*

In re Aftermarket Automotive Lighting Products Antitrust Litigation (C.D. Cal.)*

In re Pool Products Distribution Market Antitrust Litigation (E.D. La.)*

In re Wells Fargo Collateral Protection Insurance Litigation (C.D. Cal.)

Howard Hess Dental Labs, et al. v. Dentsply Int’l, Inc. (D. Del.)*

In re Warfarin Sodium Antitrust Litigation (D. Del.)*

In re Lorazepam and Clorazepate Antitrust Litigation (D. D.C.)*

In re Disposable Contact Lens Antitrust Litigation (M.D. Fla.)

In re Florida Cement and Concrete Antitrust Litigation (S.D. Fla.)*

In re Marine Hose Antitrust Litigation (S.D. Fla.)*

In re Photochromic Lens Antitrust Litigation (M.D. Fla.)*

In re Food Service Equipment Hardware Antitrust Litigation (N.D. Ga.)*

In re Aftermarket Filters Antitrust Litigation (N.D. Ill.)*

Washington County Health Care Authority, Inc. d/b/a Washington County Hospital & Nursing Home, et al. v. Baxter International Inc., et al. (N.D. Ill.)

Dahl, et al. v. Bain Capital Partners, LLC et al. (D. Mass.)

8 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 80 of 228 PageID# 11275

COURT-APPOINTED LEADERSHIP IN ANTITRUST CASES CONTINUED

In re Automotive Parts Antitrust Litigation, (41 separate actions) (E.D. Mich.)

In re Vehicle Carrier Services Antitrust Litigation (D.N.J.)

Animalfeeds International Corp. v. Stolt-Nielsen SA (S.D.N.Y.)*

In re Air Cargo Shipping Services Antitrust Litigation (E.D.N.Y.)

In re Buspirone Antitrust Litigation (S.D.N.Y.)*

In re Crude Oil Commodity Futures Litigation (S.D.N.Y.)

In re Keurig Green Mountain Single-Serve Coffee Antitrust Litigation (S.D.N.Y.)

In re Maltol Antitrust Litigation (S.D.N.Y.)*

In re Natural Gas Commodity Litigation (S.D.N.Y.)*

In re Optiver Commodities Litigation (S.D.N.Y.)

In re Oxycontin Antitrust Litigation (S.D.N.Y.)*

In re Payment Card Interchange Fee and Merchant Discount Antitrust Litigation (E.D.N.Y.)

In re Stock Exchanges Options Trading Antitrust Litigation (S.D.N.Y.)*

In re Foundry Resins Antitrust Litigation (S.D. Ohio)*

In re Polyurethane Foam Antitrust Litigation (N.D. Ohio)

Vista Healthplan, Inc. v. Sanofi-Aventis C.A. (S.D. Ohio)*

In re Flat Glass II Antitrust Litigation (W.D. Pa.)*

Anastasio, et al. v. Total Gas & Power North America, Inc. (S.D.N.Y.)

In re Merck Mumps Vaccine Antitrust Litigation (E.D. Pa.)

In re Puerto Rican Cabotage Antitrust Litigation (D.P.R.)*

In re Local TV Advertising Antitrust Litigation (N.D. Ill.)

County of Monmouth, New Jersey v. Florida Cancer Specialists, et al. (M.D. Fla.)

*Prior to joining Robins Kaplan LLP.

9 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 81 of 228 PageID# 11276

ANTITRUST RECOGNITION

I know the plaintiffs’ counsel by experience. They are all top-end lawyers.

– JUDGE BRIAN COGAN Transcript of Civil Cause for Fairness Hearing at 13, In re Air Cargo Shipping Services Antitrust Litigation (E.D.N.Y., March 24, 2016)

“Each of you have demonstrated extreme competence, respect for the court, and diligence in your work . . . You are certainly amongst the best attorneys with whom I have had the opportunity to work. Let me thank you for your professionalism in this case.”

– Judge Marianne O. Battani In re Automotive Parts Antitrust Litigation (E.D. Mich., June 4, 2020)

“[G]reat papers. Great oral argument.” – Judge Andrew J. Guilford Transcript of Motion Hearing at 49, In re Wells Fargo Collateral Protection Insurance Litigation (C.D. Cal., June 18, 2018)

“Settlement Class Counsel are highly experienced practitioners in complex litigation generally and antitrust litigation specifically. In addition, Settlement Counsel has been consistently commended in this case, deservedly so.” – Judge John Gleeson Memorandum and Opinion Granting Approval of the Lufthansa Settlement at 28, In re Air Cargo Shipping Services Antitrust Litigation (E.D.N.Y., Sept. 25, 2009)

10 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 82 of 228 PageID# 11277

ANTITRUST RECOGNITION CONTINUED

“They are good at making cost efficiencies and understanding the business aspects.”

– Client Comment, Chambers USA, 2019

Attorneys were “very responsive” and offered “really good insights into the navigation of the demands and requirements of regulators.”

– Client Comment, Chambers USA, 2019

“They are simply amazing; they are forward-thinking, creative and very effective. They do a marvelous job.”

– Peer Comment, Chambers USA, 2018

“I think the team is outstanding: Very smart, effective and great to work with – they are top shelf.”

– Peer Comment, Chambers USA, 2018

“Receives widespread praise for its capabilities in all types of antitrust matters but has achieved particularly significant success on behalf of plaintiff clients. Demonstrates considerable trial experience and knowledge of government agencies.” – Client Comment, Chambers USA, 2015

They are easy to get along with, straightforward and get the job done.

– CLIENT COMMENT Chambers USA, 2019

11 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 83 of 228 PageID# 11278

ANTITRUST RECOGNITION CONTINUED

CHAMBERS USA

Antitrust Nationwide: Band 1 Antitrust New York: Band 1 Antitrust Minnesota: Band 1 2014-2020 2014-2020 2014-2020

GLOBAL COMPETITION REVIEW

“Regional Firm of “Litigation of the Year – “GCR 100” the Year” Shortlist Cartel Prosecution” Shortlist 2017 2017-2020 Automotive Parts, 2021

LAW360

“Most Feared “Litigation “Competition Practice Plaintiffs Firms” Powerhouse” Group of the Year” 2014-2015 2016 inaugural list 2014–2015

THE LEGAL 500

One of the nation’s top firms in the area One of the best plaintiffs’ firms in the country in of Antitrust: Civil Litigation/Class Actions Class Action: Plaintiff Representation – Antitrust 2016-2020 2015

12 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 84 of 228 PageID# 11279

THE ROBINS KAPLAN TEAM

1313 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 85 of 228 PageID# 11280

WILLIAM V. REISS

Partner | New York Antitrust and Trade Regulation

William V. Reiss has nearly two decades of experience representing both plaintiffs and defendants in high profile CONTACT antitrust litigation. [email protected] Mr. Reiss was a member of the successful trial team in the precedent-setting antitrust litigation captioned Coalition 212.980.7408 for a Level Playing Field, L.L.C. v. AutoZone, Inc., 00-cv- 00953-LDW (E.D.N.Y.).

EDUCATION Mr. Reiss focuses his practice on complex antitrust litigation and class actions. Mr. Reiss also provides New York University School of Law, J.D. (2001); extensive antitrust counseling work on behalf of generic Staff Editor, pharmaceutical companies. He currently serves as co-lead Environmental Law Journal class counsel on behalf of a class of end-payor purchasers The George Washington University, of automobiles in In re Automotive Parts Antitrust B.A. in Political Science and History, Litigation for which he has been instrumental in achieving magna cum laude, Phi Beta Kappa (1998) the largest indirect purchaser recovery in U.S. history (more than $1.2 billion in settlements to date). Mr. Reiss is also co-lead counsel in In re Keurig Green Mountain Single- Serve Coffee Antitrust Litigation, a proposed class action BAR AND COURT which alleges that Keurig obtained an unlawful monopoly ADMISSIONS through a multifaceted scheme of anticompetitive New York acquisitions, exclusive dealing, and sham patent litigation.

U.S. District Court, He was recently named an “Up and Coming” Attorney, Southern District of New York Chambers USA (2020).

U.S. District Court, Mr. Reiss is committed to pro bono work and has Eastern District of New York successfully advocated on behalf of the families of the U.S. Court of Appeals, Sixth Circuit victims of the 9/11 attacks in several pro bono World Trade Center Victims’ Compensation Fund hearings before the Special Master, Kenneth R. Feinberg. He currently provides pro bono representation on behalf of immigrant children who have suffered abuse and/or neglect in their home countries.

14 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 86 of 228 PageID# 11281

RECENT NOTABLE RECOGNITIONS WILLIAM V. REISS CONTINUED

AWARDS » Named an Up and Coming Attorney, Chambers USA (2020) » Recipient of the Outstanding Antitrust Litigation Achievement in Private Practice Award, American Antitrust Institute (2019) » Named an Antitrust and M&A Trailblazer, The National Law Journal (2018) » Outstanding Antitrust Litigation Achievement by a Young Lawyer, American Antitrust Institute (2016) » Named a Rising Star, Law360 (2016) » Named a Rising Star, New York Law Journal (2014)

WRITINGS » No-Poach Antitrust Standard Unclear in Franchising Law360 (October 23, 2020) » 7th Circuit Ruling Solidifies Circuit Split On Antitrust Standing Law360 (April 22, 2020) » If There, Then Here: How Gov’t Probes Help Antitrust Plaintiffs Law360 (March 18, 2019) » Antitrust Plays Whack-a-Mole as Exclusion of Competition by Drug Monopolists Pops Up Again: Gaming the ‘REMS NYLitigator (Fall 2016) » Revisiting the Applicability and Scope of Daubert at Class Certification Three Years after Comcast v. Behrend Antitrust Health Care Chronicle (February 2016) » Where Does a Fresh Start End?: The Case for Imposing Joint and Several Liability on a Reorganized Debtor that Continues to Participate in an Antitrust Conspiracy Post-Discharge Bloomberg BNA Antitrust & Trade Regulation Report (October 25, 2013) » Duking it Out in Antitrust Price-Fixing: Class Actions After Dukes CPI Antitrust Chronicle (August 2011) » The Duchesses Come Out Swinging in Dukes: Restoring the Balance in Class Certification The CPI Antitrust Journal (August 2010) » On Life Support from Leeginaire’s Disease: Can the States Resuscitate Dr. Miles? Antitrust Magazine (Summer 2008)

15 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 87 of 228 PageID# 11282

SPEAKING ENGAGEMENTS/LECTURES WILLIAM V. REISS CONTINUED

» Health Care Antitrust Under President Biden Robins Kaplan LLP, Webinar (March 9, 2021) » Pleading and Defending Coordinated Conduct Claims Moderator, American Bar Association, Webinar (February 26, 2021) » Discovering a Hidden Revenue Stream: Recoveries from Antitrust Class Action Settlements in Economic Downturn Webinar, Robins Kaplan LLP (July 21, 2020) » The Butterfly Effect: When the Little Things Made a Huge Difference in My Antitrust Case New York State Bar Association, Antitrust Law Section and Corporate Counsel Section, New York, New York (January 30, 2020) » Antitrust Plus Factors New York State Bar Association, Antitrust Law Section, New York, New York (February 27, 2019) » Discovering a Hidden Revenue Stream: Recoveries from Antitrust Class Action Settlements Webinar, Robins Kaplan LLP (January 29, 2019) » Don’t Be Afraid of the DARC Panel, New York State Bar Association (January 17, 2019) » Is Direct Really Correct Bricks Tix Kicks and Apps After Apple V Pepper Panel, American Bar Association (October 2, 2018) » Should I stay or Should I go? Robins Kaplan Webinar (May 15, 2018) » Negotiating Cartel Fines and Civil Settlement Panel, American Bar Association Spring Meeting, Washington, DC (April 10, 2018) » Antitrust Class Actions University of Florida, Gainesville, Florida (via videoconference) (October 4, 2017) » REMS and Other Drug Distribution Restrictions: When Does a Brand Company Have a Duty to Deal with its Generic Rivals? New York State Bar Association, New York, New York (November 3, 2016) » What Do Recent Decisions Mean for Indirect Purchaser Class Actions in the US Panel, American Bar Association (July 24, 2015)

ORGANIZATIONS

» New York State Bar Association, Antitrust Law Section Executive Committee Member and Membership Chair » American Bar Association Section of Antitrust Law » KIND (Kids In Need of Defense), Volunteer Lawyer

16 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 88 of 228 PageID# 11283

KELLIE LERNER

Co-Chair | Antitrust and Trade Regulation Partner | New York

Kellie Lerner has nearly two decades of experience litigating high stakes antitrust disputes on behalf of both plaintiffs and defendants in federal courts throughout the country. Ms. Lerner currently serves in leadership positions in In CONTACT re Merck Mumps Vaccine Antitrust Litig., In re Hard Disk Drive Suspension [email protected] Assemblies Antitrust Litig. and Sterk, et al. v. The Bank of Nova Scotia, et al. and previously represented a publicly traded corporation where she successfully 212.980.7406 obtained a complete dismissal of a federal and multi-state antitrust class action filed against her client. She also counsels generic pharmaceutical, alternative energy and entertainment companies on competition issues. Ms. Lerner is also principally responsible for identifying and initiating new antitrust actions at the EDUCATION firm. In this capacity, she has initiated the first antitrust class action lawsuits in Rutgers Law School, Dean’s Merit the country in dozens of actions that have ultimately resulted in billions of Scholar, J.D. (2003) dollars in recoveries for victims of anti-competitive conduct. In 2020, Ms. Lerner was selected by the New York Law Journal for its Rutgers University, B.A., cum laude, Phi “Distinguished Leader” award, which honors attorneys in leadership positions Beta Kappa (1999) who achieved impressive and positive results over the past year. In 2019, the National Law Journal named her as one of the “Elite Women of the Plaintiff’s Bar,” and the New York Law Journal recognized her as a “New York Trailblazer.” Ms. Lerner has also been recognized for the last three consecutive years as a BAR AND COURT notable practitioner in Antitrust law in the Chambers USA Guide, in which she ADMISSIONS was praised by her peers for her ability to “get large teams of people to work effectively together.” In recent years, she has also been selected by Benchmark New York Litigation as a “Future Star” (2018-2020), by The National Law Journal as an New Jersey “Antitrust and M&A Trailblazer” (2016), by The New York Law Journal as one of U.S. Court of Appeals, Second Circuit 44 competition lawyers under 40 “who have made their mark on the New York U.S. District Court, Southern District of legal community,” and by Law360 in its “Rising Star” list of five competition New York lawyers under the age of 40 to watch. The Legal 500 USA has also praised Ms. Lerner for her “superior intellect, determination and political savvy in getting U.S. District Court, New Jersey the job done.” In 2018, she was the recipient of Inside Counsel’s “National Women in Law” Award. A frequent author and lecturer, Ms. Lerner is a recognized voice on all issues of antitrust law and her opinions have been quoted in The Washington Post, Bloomberg Businessweek, Yahoo News, and CBS MoneyWatch, among other publications. Ms. Lerner is a member of the Executive Committee and Chair of Diversity for the Antitrust Section of the New York State Bar Association, a member of the Advisory Board of the Institute of Consumer Antitrust Studies of the Loyola University Chicago School of Law, Co-Chair of the National Association of Women Lawyers’ Litigation Affinity Group, Secretary of The Committee to Support the Antitrust Laws (COSAL) and an Editor of Antitrust magazine. Ms. Lerner co-founded Roseann’s Gift, an organization named for her late mother and dedicated to raising research funding to cure lung cancer. The organization is funding lung cancer research at Weill Medical College of Cornell University. She is a member of the Tri-State Area Advisory Board of Jumpstart, which works to provide equal access to literacy education for preschool children in under-resourced communities and was previously a member of the Board of Directors for the Jewish Community Project Downtown, an organization that was formed in the wake of the September 11th attacks to revitalize the Jewish community in lower Manhattan. She currently provides pro bono assistance to KIND (Kids In Need of Defense) and has previously provided assistance to the Transgender Legal Defense and Education Fund, AARP and the Lawyers Committee for Civil Rights Under the Law.

17 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 89 of 228 PageID# 11284

RECENT NOTABLE RECOGNITIONS KELLIE LERNER CONTINUED

AWARDS » Listed in Who’s Who Legal: Competition (2020) » Named “Notable Woman in Law,” Crain’s New York Business (2020) » New York Law Journal Distinguished Leader (2020) » The National Law Journal Elite Women of the Plaintiff’s Bar (2019) » New York Law Journal, New York Trialblazer (2019) » Corporate Counsel/InsideCounsel National Women in Law (2018) » The National Law Journal Antitrust Trailblazer (2016) » Profiles in Diversity Journal Diversity Leader (2017) » Profiles in Diversity Journal Woman Worth Watching (2015) » New York Law Journal Rising Star (2013) » Law360 Competition Rising Star (2012)

**Being named to the list or receiving the award is not intended and should not be viewed as comparative to other lawyers or to create an expectation about results that might be achieved in a future matter. RANKINGS » Chambers USA: Antitrust New York: Band 1 (2018-20) » Benchmark Litigation: Future Star (2016-17, 2019-20) » New York Super Lawyer (2018-19) » The Legal 500: Recommended (2013-16)

WRITINGS » A Perfect Storm: Health Care Consolidation and the Lack of Antitrust Enforcement American Bar Association (Summer 2020) » No-Poachers Find Themselves in Hot Water Bloomberg Law (Aug. 29, 2018) » Judges Can Demand Diversity In Rule 23(g) Applications Law360 (Aug. 15, 2018) » How Do You Solve a Problem Like Algorithmic Price Fixing? Bloomberg Law (Feb. 8, 2018) - Nominated as one of 10 articles in the Business Articles: Concerted Practices category for Concurrence’s 2019 Antitrust Writing Awards » Addressing the Gender Divide in the Courtroom New York Law Journal (Sept. 8, 2017) » Consumer Protection Developments: New Challenges and Unanswered Questions Antitrust Magazine (July 10, 2017) » The 9th Circ.’s Rule 6(e) Test For Private Antitrust Cases Law360 (Oct. 20, 2015) » Early Lessons From The REMS Battlefield Law360 (Mar. 9, 2015) » Tech-Tying Vs. Section 2 Of The Sherman Antitrust Act Law360 (Dec. 4, 2014) » The 5 Hidden Benefits of a Diverse Legal Team InsideCounsel (Nov. 17, 2014) » It’s Time to Revisit Antitrust Penalties Daily Journal (Oct. 28, 2014) » DOJ Stays Are Often Unfair To Private Antitrust Plaintiffs Law360 (Mar. 3, 2014) » 5 Overlooked Reasons to Be Class Rep in an Antitrust Suit Law360 (May 16, 2013) » When You Lose the Race to Corporate Leniency Law360 (Mar. 15, 2013) 18 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 90 of 228 PageID# 11285

SPEAKING ENGAGEMENTS/LECTURES KELLIE LERNER CONTINUED

» Leading Voices in Private Enforcement: Insights on Bringing and Litigating Successful Antitrust Cases Panelist, 14th Annual Private Antitrust Enforcement Virtual Conference (November 12, 2020) » Are You Down with APP (Algorithmic Pricing) Webinar, American Bar Association (November 3, 2020) » A Conversation With Women in Government Antitrust Enforcement Moderator, New York Women in Antitrust Panel, New York, New York (May 28, 2020) » Noerr-Pennington Immunity and “Sham” Petitioning Developments in the Pharmaceutical Industry New York State Bar Association, New York, New York (April 9, 2019 » Blunt Instrument or Surgical Blade: Is Section 2 of the Sherman Act the Right Tool to Address Financial Market Manipulation? New York State Bar Association, New York, New York (January 17, 2019) » New Revenue Streams: Analyzing Antitrust Class Action Settlement Claims Bloomberg Law Webinar (Apr. 10, 2019) » Role of Market Power in the Digital Economy New York State Bar Association (January 25, 2018) » Women in Antitrust – The Times They Are A-Changing New York State Bar Association – Antitrust Law Section (January 24, 2018) » Class Action Reform: Necessary or Nocuous? American Bar Association (January 17, 2018) » Class Action Settlements for Antitrust Practitioners and In-House Counsel Practising Law Institute (June 21, 2017) » 5 Hidden Benefits of a Diverse egalL Team Robins Kaplan LLP Webinar (March 3, 2015)

ORGANIZATIONS » New York State Bar Association, Antitrust Section; Executive Committee Member and Chair of Diversity » National Association of Women Lawyers, Litigation Affinity Group Co-Chair » American Bar Association, Section of Antitrust Law; Editor, Antitrust Magazine » The Committee to Support the Antitrust Laws, Secretary » Institute of Consumer Antitrust Studies of the Loyola University Chicago School of Law, Advisory Board Member » Robins Kaplan New York Women in Antitrust Group, Chair

19 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 91 of 228 PageID# 11286

ADAM C. MENDEL

Associate | New York Antitrust and Trade Regulation

CONTACT Adam C. Mendel focuses his practice on prosecuting complex [email protected] antitrust class actions involving price fixing, unlawful monopolization, and other anticompetitive practices. He has 212.980.2342 represented clients throughout the litigation process, from complaints and motions to dismiss through summary judgment and settlement. Mr Mendel is also a member of the Robins EDUCATION Kaplan LLP COVID-19 Task Force, where he provides guidance University of Pennsylvania on the Coronavirus Aid, Relief, and Economic Security Law School, J.D. (2016); (“CARES”) Act and other changes in the legal environment. Wharton Certificate in Management; University of Pennsylvania Prior to joining Robins Kaplan LLP, Mr. Mendel worked as a Journal of Constitutional Law, litigator at a large New York law firm where he maintained a Executive Editor, Volume 18 diverse practice, working on insurance, bankruptcy, white-collar, and general commercial matters. From 2018-2019, he served as Northwestern University, B.A. in Political Science, International Studies, a judicial law clerk to the Hon. William T. Lawrence of the and Latino Studies, magna cum laude, United States District Court for the Southern District of Indiana. Phi Beta Kappa (2013) Mr. Mendel is committed to pro bono work, and regularly assists immigrants fleeing persecution in their home countries in obtaining legal status in the United States. BAR AND COURT ADMISSIONS New York

20 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 92 of 228 PageID# 11287

RECENT NOTABLE RECOGNITIONS ADAM C. MENDEL CONTINUED

AWARDS » Named Empire State Counsel for pro bono service (2017) » University of Pennsylvania Law School Award for Exceptional Service (2016) » Fellowship at Auschwitz for the Study of Professional Ethics (2015)

WRITINGS » If Your Company Received a Paycheck Protection Loan - The SBA Wants to Know How Necessary was Your Loan Robins Kaplan LLP (November 12, 2020) » Big Data In The Wake Of COVID-19 – A Conundrum For Enforcers Bloomberg Law (June 17, 2020) » Joint Ventures And The COVID-19 Pandemic Thomson Reuters, Westlaw (May 26, 2020) » States Must Toll Court Deadlines To Ensure Access To Justice Law360 (April 5, 2020) » Summary Of Cares Act Relief Provisions And Application Process Robins Kaplan LLP (April 1, 2020) » Did Antitrust Enforcers Allow For Creation Of Competitive Ecosystem Now Drawing Their Ire? Bloomberg Law (March 31, 2020) » How Policy Makers Can Support The Public’s Access To Justice During COVID-19 – Toll The Deadlines To File New Claims Robins Kaplan LLP (March 26, 2020) » Unintended Consequences: How a DOJ Antitrust Investigation Could Exacerbate Global Warming The National Law Journal (December 17, 2019) » Lawyers and the Ethical Use of Precedent 2015 FASPE J. 4 (2016) » The First AUMF: The Northwest Indian War, 1790-1795, and the War on Terror 18 U. Pa. J. Const. L. 1309 (2016)

ORGANIZATIONS » Hispanic National Bar Association » New York State Bar Association

21 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 93 of 228 PageID# 11288

ROBINSKAPLAN.COM

05032021 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 94 of 228 PageID# 11289

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Robins Kaplan LLP Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Hollis Salzman P 8.2 $900.00 $7,380.00 Hollis Salzman P 255.9 $925.00 $236,707.50 Hollis Salzman P 265.1 $1,100.00 $291,610.00 Kellie Lerner P 40.7 $800.00 $32,560.00 Kellie Lerner P 3.7 $825.00 $3,052.50 Kellie Lerner P 4.9 $890.00 $4,361.00 Kellie Lerner P 1.5 $935.00 $1,402.50 Meegan Hollywood P 3.2 $740.00 $2,368.00 Meegan Hollywood P 1.1 $800.00 $880.00 Meegan Hollywood A 1.0 $700.00 $700.00 William Reiss P 56 $750.00 $42,000.00 William Reiss P 495 $775.00 $383,625.00 William Reiss P 721 $855.00 $616,455.00 William Reiss P 21.1 $900.00 $18,990.00 Eamon O’Kelly OC 3.5 $900.00 $3,150.00 Adam Mendel A 126.8 $560.00 $71,008.00 Adam Mendel A 48.6 $630.00 $30,618.00 Matthew Geyer A 68.8 $560.00 $38,528.00 Matthew Geyer A 1.5 $630.00 $945.00 Matthew Cardosi A 89.7 $670.00 $60,099.00 Nahid A. Shaikh A 116.5 $465.00 $54,172.50 Nahid A. Shaikh A 0.6 $545.00 $327.00 Nathaniel C. Ament-Stone A 10.0 $465.00 $4,650.00 Nathaniel C. Ament-Stone A 13.6 $545.00 $7,412.00 Noelle Feigenbaum A 7.0 $445.00 $3,115.00 Noelle Feigenbaum A 993.1 $545.00 $541,239.50 Noelle Feigenbaum A 883.3 $560.00 $494,648.00 Noni Nelson A 5.1 $540.00 $2,754.00 Noni Nelson A 12.5 $545.00 $6,812.50 Qian Julie Wang A 6.4 $540.00 $3,456.00 Tai Milder A 1.8 $750.00 $1,350.00 Vincent A. Licata A 4.5 $465.00 $2,092.50 Vincent A. Licata A 10.4 $490.00 $5,096.00 Ashley N. Emershaw PL 20.2 $320.00 $6,464.00 Ashley N. Emershaw PL 6.0 $330.00 $1,980.00 Audra M. O'Rourke PL 17.8 $310.00 $5,518.00 Audra M. O'Rourke PL 15.6 $320.00 $4,992.00 Audra M. O'Rourke PL 4.8 $400.00 $1,920.00 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 95 of 228 PageID# 11290

Jeffrey Baum PL 24.2 $325.00 $7,865.00 Jeffrey Baum PL 117 $335.00 $39,195.00 Mabel Marte PL 12.7 $250.00 $3,175.00 Mabel Marte PL 29.8 $315.00 $9,387.00 Peggy Arman PL 48.6 $390.00 $18,954.00 Peggy Arman PL 12.4 $410.00 $5,084.00 Ryan S. Willoughby PL 0.7 $325.00 $227.50 Ryan S. Willoughby PL 99.3 $335.00 $33,265.50 Ryan S. Willoughby PL 24.9 $425.00 $10,582.50 Andrew Borer E 1.3 $185.00 $240.50 Elizabeth Omodt E 2.9 $185.00 $536.50 Heather Willy E 59.9 $225.00 $13,477.50 Heather Willy E 25.6 $250.00 $6,400.00 Katrina Stewart E 8.2 $160.00 $1,312.00 Linda Banks E 3.8 $300.00 $1,140.00 Lynn Brinkman E 8.3 $160.00 $1,328.00 Marina Schlesinger E 2.4 $250.00 $600.00 Melissa Olson E 14.5 $160.00 $2,320.00 Renae L. Knudson E 7.9 $225.00 $1,777.50 Roger Smith E 19.3 $160.00 $3,088.00 Scott Schermerhorn E 20.6 $160.00 $3,296.00 Theodore J. Harwood E 13.9 $160.00 $2,224.00 Vivian Enck E 381.5 $300.00 $114,450.00 Reed J. Ackerman E 812.8 $160.00 $130,048.00 TOTALS 6,099.0 $3,404,412.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) eDiscovery (E) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 96 of 228 PageID# 11291

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Robins Kaplan LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $4,760.35 Filing / Misc. Fees $1,779.63 Overnight Delivery/Messengers $651.34 Photocopying $1,920.47 Postage $0.00 Service of Process Fees $0.00 Telephone / Fax $698.20 Transportation / Meals / Lodging $24,171.96 Litigation Fund Contributions $612,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 eDiscovery* $22,759.90 TOTAL $668,741.85

* Robins Kaplan hosted the platform for Indirect Purchaser Plaintiffs' document collection and production, and billed for this service at market rates. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 97 of 228 PageID# 11292

Exhibit A-3 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 98 of 228 PageID# 11293

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DI.STRICT OF VIRGINIA Richmond Dil'ision

IN RE: INTERIOR MOLD ED DOORS Lead Civ il Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF STEVEN N. WILLIAMS IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN A WARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Steven N. Will iams, hereby declare as fol lows:

I. I am a duly licensed attorney in California and am admitted pro hac vice in th is

Court. I am a partner at the Joseph Saveri Law Firm, LLP ("JSLF"). On December 26, 20 I 8, the

Court appointed me as one of Interim Co -Lead Counsel in the above-captioned action ("Action"),

and on February 5, 202 I, my firm was appointed Settl ement Class Counsel along with Gustafson

Gluck, Pl.LC and Robins Kaplan, LLP. I submit this declaration pursuant to 28 U.S.C. § l 746 in

support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees, Reimbursement

of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if cal led upon, I cou ld

and would competently testify thereto.

3. My firm has served as Interim Co-Lead Counsel and Seulement Class Counsel for

the Indirect Purchaser Plaintifls in this litigation on an entirely contingent basis. The background

and experience of JSLF and its attorneys are summarized in the firm resume attached hereto as

Exhibit A.

4. The schedule attached as Exhibit 13 sets forth my firm's tota l hours and attorneys' Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 99 of 228 PageID# 11294

fee lodestar in this litigation. This includes work performed by my firm's attorneys and

professional staff, computed at my fum's historical hourly rates from inception through f-ebruary

28, 202 1.

5. The total number of hours expended in this litigation by my iirm from inception

through Februa11' 28, 2021 is 6,089.50. The lOtal lodeswr for my firn1 is $2,812,261.5 0. The total

attorney and professional staff time reflected in this declaration is based on my firn,'s

contemporaneous, daily time records regularly prepared and maintained by my firm, as well as

any reductions applied to avoid duplication and ensure efficiency.

6. All of the services performed by my fi rm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of serv ices for wh ich my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $775,406.89 in

unreimbursed cosls and expenses in lhis litigation during the period from inception of this case

through March 31, 2021, including $612.000.00 in contributions to the Indirect Purchaser

Plaintiffs' joint litigation fund. My firm advanced these costs and expenses with no assurance that

such costs and expenses would be repaid.

8. The costs and ex penses incurred in this action are reflected on the books and records

of my fi rm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessa1i ly incurred in connection with this litigation. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 100 of 228 PageID# 11295

9. I decla re under pena lty ofpe1ju1y that the foregoing is true and correct.

even N. Will iams ,JOSEPH SAVERI LAW FIRM, LLP Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 101 of 228 PageID# 11296

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 102 of 228 PageID# 11297

SAN FRANCISCO, CA NEW YORK, NY 2021

Joseph Saveri Law Firm, LLP Firm Resume Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 103 of 228 PageID# 11298

FIRM HISTORY AND BACKGROUND

The Joseph Saveri Law Firm, LLP is one of the country’s most acclaimed and successful boutique firms. It achieves ground-breaking results for plaintiffs in antitrust law, class actions, complex business disputes, securities litigation, consumer protection, intellectual property, and qui tam/whistleblower cases, in federal and state courts throughout the United States and across the globe.

saverilawfirm.com 2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 104 of 228 PageID# 11299

FIRM HISTORY AND BACKGROUND JOSEPH SAVER! LAW FIRM

The Firm was founded in 2012 by Joseph Saveri. Since then, it has led several groundbreaking and precedent-setting cases. It has served as lead and co- counsel on a variety of cases involving: challenges to price-fixing; monopolization; illegal reverse payments; “pay-for-delay” agreements involving the drugs Cipro, Lidoderm, Restasis, and Opana ER; and “no-poach” agreements restricting hiring and recruiting at major corporations. These cases cover diverse industries including pharmaceuticals, high-technology, electronics, banking and financial services, transportation, and sports leagues.

The Firm is widely regarded as one of the nation’s leading law firms; it has established a track record leading and prosecuting some of the most significant cases across the United Sates. Its attorneys have recovered over $4 billion in settlements and successful resolutions for their clients, and the Firm has received many honors, including:

Firm Awards AMERICAN ANTITRUST INSTITUTE In 2020, Anupama Reddy was recognized by the American Antitrust * * Institute for “Outstanding Antitrust Litigation Achievement by a Young Lawyer” (for work performed in In re Capacitors Antitrust Litigation). In AMERICAN 2017, the Firm was an Honoree for “Outstanding Antitrust Litigation ANTITRUS Achievement in Private Law Practice” for its success in In re Cipro INSTITUTE Cases I and II. In 2015, the Firm was a Finalist for this award for its success in In re High-Tech Employee Antitrust Litigation. The awards are part of the American Antitrust Institute’s Antitrust Enforcement Awards, which recognize achievements in antitrust litigation by legal practitioners and economists.

BENCHMARK LITIGATION In the practice area of “competition/antitrust,” the Firm was recognized as one of the top five in California. Partners Joseph Saveri and Steven Williams were honored in the same field as “National Practice Area Stars” and “Local Litigation Stars.” (2020)

Benchmark Litigation, based in the United Kingdom, New York City, and Hong Kong, researches and ranks law firms and lawyers based on transactional advice. Research is conducted through extensive interviews with litigators, dispute resolution specialists, and their clients to identify the leading litigators and firms. During these interviews, it examines recent casework handled by law firms and ask individual litigators to provide their professional opinions on peers and practitioners within their jurisdiction or practice area. Each annual research process culminates in the publication of law firm rankings, individual lawyer ratings, and firm editorial content. saverilawfirm.com 3 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 105 of 228 PageID# 11300

FIRM HISTORY AND BACKGROUND JOSEPH SAVER! LAW FIRM

Firm Awards Con’t BEST LAWYERS/U.S. NEWS & WORLD REPORT * Since 2013, the Firm has been annually selected for inclusion in Best Law Firms, an annual publication by U.S. News & World Report and Best Lawyers. It is ranked among the top tiers in “Litigation—Antitrust” nationally, Best Lawyers and “Litigation—Antitrust” and “Mass Tort Litigation/Class Actions” in San BEST Francisco. Firms included in the Best Law Firms list are recognized for LAW FIRMS professional excellence with persistently impressive ratings from clients and peers. Achieving a tiered ranking signals a unique combination of quality law practice and breadth of legal expertise. To be eligible for a ranking, a firm must have a lawyer selected by Best Lawyers to The Best Lawyers in America, a publication which recognizes the top five percent of practicing attorneys in the United States. Joseph Saveri and Steven Williams have been meritoriously selected.

CHAMBERS AND PARTNERS Chambers and Partners has ranked The Firm “Band 1” (highest ranking) in f TOP RANKED • its “Antitrust: Mainly Plaintiff—California” category: currently the only firm in ~ Chambers ~ California to receive this honor. Chambers recognized the Firm as ' USA • “esteemed for securing significant victories in monopolization, price-fixing ~-,2020,.~ and pay-for-delay cases.” It found it to be “among the top plaintiffs’ firms in the country; a very well-known firm that shows up in important cases.” Jrn1:q1h Savcri Law Firm, Inc.

Firm partners Joseph Saveri and Steven Williams are currently ranked “Band 1” attorneys by Chambers in its “Antitrust: Plaintiff—USA— Nationwide” and “Antitrust: Mainly Plaintiff—California” categories. Their dual “Band 1” rankings make the Firm the only one nationwide to contribute multiple “Band 1” designees to these categories. Joseph Saveri has been ranked a “Band 1” attorney in these categories since 2014. Chambers commended him for “leading class action litigation against industry giants in the tech, pharmaceutical and manufacturing sectors” and his “market- leading expertise in price-fixing, monopolization and conspiracy claims.” His legal peers described him as “a tenacious attorney who turns difficult cases into good cases.” Steven Williams has been ranked “Band 1” or “Band 2” in one or both categories since 2015. He has been praised for his “deft representation of plaintiffs across an array of anticompetitive issues in federal and state court” and his “strong track record leading large plaintiff classes in industry-significant price-fixing litigation.”

London-based Chambers ranks law firms and individual lawyers in bands from 1-6, with 1 being the best. The qualities on which rankings are assessed include technical legal ability, client service, commercial vision and business understanding, diligence, value for money (cost-effective staffing and organization), depth of team, professional conduct, and other factors important to clients.

DAILY JOURNAL (CALIFORNIA) The Firm was recognized as one of the “Top Boutiques in California 2018,” a contest that selected and reported on the top 20 boutique law firms in California. The profile highlighted the Firm’s recent growth, the addition of partner Steven Williams, and its advancement of antitrust law on prominent cases such as In re Cipro Cases I and II. The Firm also received this award in 2016. Joseph Saveri and Steven Williams have received several Daily Journal “Top in California” individual awards in various categories.

The Daily Journal Corporation, a Los Angeles-based publishing and technology company, features Interview-based profiles covering judicial saverilawfirm.com philosophy, representative decisions, and recent cases. 4 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 106 of 228 PageID# 11301

FIRM HISTORY AND BACKGROUND JOSEPH SAVER! LAW FIRM

LAWDRAGON Firm Awards Con’t Joseph Saveri and Steven Williams have been selected 2019-present for * Lawdragon legal media company’s “500 Leading Plaintiff Financial Lawyers” 500 online guide. The guide, first published in 2007, presents Lawdragon’s LEADING PLAINTIFF recognition of the best of the U.S. plaintiff bar. The 500 lawyers selected FINANCIAL LAWYERS bring their cases as individual matters as well as in class actions that are increasingly going global. Lawdragon, based in New York City, provides free I• I online news and editorial features—including its well-known guides to the nation’s leading lawyers—as well as content, marketing, and branding services for lawyers and firms.

THE LEGAL 500 In 2019-present, the Firm was one of a select few nationwide recognized for excellence in the United Kingdom-based research and ranking service’s “United States Antitrust Civil Litigation/Class Actions: Plaintiff” category. The Legal 500 LEGAL assesses the strengths of law firms in over 150 jurisdictions. Its rankings are based on feedback from 300,000 clients worldwide, detailed submissions from law firms, 500 interviews with leading private practice lawyers, and a team of researchers with unrivaled experience in the legal market.

MARTINDALE HUBBELL Two Firm partners have achieved Martindale Hubbell’s highest rating—“AV Mar1incfalc-Hubbcll Preeminent.” Joseph Saveri has achieved this ranking since 2008; Steven PREEMINENT Williams has done likewise since 2002. Martindale-Hubbell’s Peer Review ~t R,1tC'd for H,ohc-st l('V(>I ct Profo·•~....ontll E:iu:c-lk-nC(' Ratings are an objective indicator of a lawyer’s high ethical standards and professional ability. Attorneys receive Peer Review Ratings based on evaluations by other members of the bar and the judiciary in the United States and Canada.

SUPER LAWYERS Several of the Firm’s attorneys have been recognized by Super Lawyers, part of Thomson Reuters, which rates outstanding lawyers from more than Super 70 practice areas who have attained a high-degree of peer recognition, Lawyers professional achievement, and excellence. The Super Lawyers list recognizes no more than five percent of attorneys in each state. Partner Joseph Saveri has been rated a “Super Lawyer” annually since 2006 and was named to the “Top 100 Northern California Super Lawyers” in 2015- 2016 and 2019-present. Partner Steven Williams has been annually rated a “Super Lawyer” since 2005 and was named to the “Top 100 Northern California Super Lawyers” in 2016-present. Associate Kyle Quackenbush was rated a “Rising Star” in 2020.

WHO’S WHO LEGAL/GLOBAL COMPETITION REVIEW Firm partners Joseph Saveri and Steven Williams were selected as two of the top plaintiffs’ attorneys worldwide in Who’s Who Legal: Competition 2020, a publication of Who’s Who Legal and Global Competition Review. Mr. Saveri was praised as “a distinguished antitrust practitioner on the plaintiff side.” Mr. Williams was commended as a “top-notch competition lawyer” and a "highly intelligent strategic thinker.“ Mr. Saveri was previously selected for this honor in 2015-2019, as was Mr. Williams in 2014-2019. In 2019-present, Joseph Saveri and Steven Williams were also profiled in Thought Leaders: Competition, a publication of Who’s Who Legal.

Who’s Who Legal, a prestigious United Kingdom-based legal ranking service, has identified the foremost legal practitioners and consulting experts in business law based upon comprehensive, independent research. It is dedicated to identifying the world’s leading lawyers across multiple practice areas and publishes a series of guides throughout the year. Global Competition Review provides a subscription-based news and resource saverilawfirm.com service (both online and print) and yearly hosts several live events. 5 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 107 of 228 PageID# 11302

FIRM HISTORY AND BACKGROUND JOSEPH SAVER! LAW FIRM

With 30 years of civil litigation experience, Mr. $4B+ Saveri has handled cases involving numerous industries, including: banking and financial services, In settlements and resolutions for our insurance, energy, pharmaceuticals, agricultural clients products, computer hardware, computer software, manufacturing inputs, travel and transportation, paper products, cosmetics, and consumer electronics. He has established himself as one of the country’s top litigators in the antitrust field.

100+ Mr. Saveri has investigated, prosecuted, and successfully resolved numerous antitrust class actions and other complex cases. He has served both as a court-appointed leader of such efforts and as a valued Combined Years of member of the teams operating under the leadership of others. As lead Civil Litigation or co-lead counsel in many of these cases, he has taken a personal Experience leadership role in organizing litigation, setting strategy, establishing and directing teams of lawyers, and assigning specific tasks to teams of attorneys in a way that ensures the efficient use of resources and maximizes the talents of the litigation team. Throughout these cases, he has displayed the energy, vision, and commitment that leadership requires, combined with the ability to listen, share, and work cooperatively so that the litigation team operates equitably, efficiently, and without friction. 17 Mr. Saveri and the Firm serve or have served as lead counsel in many high-profile cases, including most recently Capacitors, Titanium Dioxide, High-Tech Employees, and California’s Cipro litigation. Over Leadership the past decade, his fellow partner Steven Williams has played a lead Positions in Cases role in many of the most prominent antitrust class cases and been Nationwide named lead or co-lead counsel more often than perhaps any other attorney in the United States. Overall, the Firm’s attorneys are accomplished and successful in all phases of litigation and have been awarded by the American Antitrust Institute, Chambers and Partners, Martindale Hubbell, The Legal 500, Who’s Who Legal, and Super Lawyers for their distinguished leadership. They lecture and write on many topics, are actively involved in numerous legal organizations, and are multi-lingual and from diverse backgrounds.

The Firm has a strong commitment to pro bono representation. It frequently works with the Northern District of California’s Federal Pro Bono Project, which operates in conjunction with the Bar Association of San Francisco’s Justice and Diversity Center. The JDC provides pro bono services to underserved San Francisco residents and communities, and the organizations that serve them. Many Firm attorneys participate in this project and have received Court praise for their successful results achieved for their clients. saverilawfirm.com 6 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 108 of 228 PageID# 11303

CASE PROFILES

The Firm has been a successful leader in cases covering antitrust, class actions, complex business disputes, consumer protection, and other practice areas, on behalf of national and international consumers, purchasers, and employees across diverse industries.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

The Firm handles antitrust cases, class actions, and complex litigation in federal and state courts throughout the United States. Prominent past and current cases in which the Firm or Mr. Saveri serves or has served include:

IN RE CAPACITORS ANTITRUST LITIGATION No. 3:14-cv-03264-JD, 3:17-md-02801-JD (N.D. Cal.)

The Firm is sole Lead Counsel for a class of direct purchasers of capacitors used in electronic devices. Plaintiffs allege that Defendants—over twenty corporations and corporate families—formed a cartel and conspired to fix, raise, and stabilize prices in the multi- billion-dollar market for aluminum, tantalum, and film capacitors. The Firm represents the class as Plaintiffs in a civil class action. Settlements totaling $439.55 million have been reached with most Defendants. Trial against Defendants who have not settled will occur in 2021. In the criminal case, eight capacitors manufacturers and two individual executives have pleaded guilty and been sentenced for violating federal antitrust laws.

IN RE CIPRO CASES I AND II J.C.C.P. Nos. 4154, 4220 (San Diego County Sup. Ct.)

The Firm is Co-Lead Counsel for consumers who purchased Cipro, a blockbuster antibiotic drug. Plaintiffs alleged that Bayer Corporation, Barr Laboratories, two other generic drug companies, and other Defendants entered into an unlawful agreement to keep a generic version of the drug off the market, which allowed Bayer to sell Cipro at inflated prices. In 2013, the California Superior Court for the County of San Diego approved a $74 million class action settlement between Bayer and the Class. In 2015, the California Supreme Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings. In that decision, the California Supreme Court ruled in Plaintiffs’ favor and adopted a “structured” rule of reason as the standard for adjudicating reverse payment antitrust cases. Following remand to the Superior Court, Plaintiffs reached a $100 million settlement agreement with Defendants Hoechst Marion Roussel, The Rugby Group, Inc., and Watson Pharmaceuticals, which the Court approved in 2016. In 2017, on the eve of trial, Plaintiffs settled with Barr, the sole remaining Defendant, for $225 million, bringing the total Class recovery to $399 million: a record for this type of case.

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CASE PROFILES JOSE LAW FIRM

SCOLA V. FACEBOOK, INC. No. 18CIV05135 (San Mateo County Sup. Ct.)

The Firm is co-counsel in an action against Facebook alleging that a Plaintiff Class of content moderators responsible for viewing and removing offensive and disturbing content from Facebook users are suffering from post-traumatic stress disorder and other trauma-related injuries because they were not being properly protected by the social media company. In 2020, the Class reached a ground-breaking preliminary settlement for $52 million and workplace improvements. The settlement provides significant relief to over 10,000 content moderators who worked for Facebook’s vendors in California, Arizona, Texas, and Florida.

IN RE HIGH-TECH EMPLOYEES ANTITRUST LITIGATION No. 5:11-cv-02509-LHK (N.D. Cal.)

The Firm served as Co-Lead Class Counsel for a class of over 60,000 employees of leading technology companies against their employers for their alleged agreements to restrict recruiting to suppress wages. Three Defendants agreed to settlements totaling $20 million. Following the Court’s denial of their motions for summary judgment, the remaining Defendants agreed to a settlement totaling $415 million.

IN RE TITANIUM DIOXIDE ANTITRUST LITIGATION \J Ct No. 1:10-cv-00318-RDB (D. Md.) Ti C rom1 ::,C- \/anad1um 51 99 Titanium 50.9415 :andiurn 47.867 \P.r\3C The Firm served as to a class of direct purchasers ,.955910 \P.r]3d1 4s2 Co-Lead Counsel [P. r]3d2 4s2 6 7E ~r13c1J/ 6 74 2 f R7P \ of titanium dioxide who alleged that several primary suppliers engaged • • r 0 42 ' 40 41 N in an unlawful conspiracy to raise, maintain, or stabilize prices for Zr Nb titanium dioxide in the United States. The case produced a $163.5 y million settlement.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

IN RE RESTASIS (CYCLOSPORINE OPHTHALMIC EMULSION) ANTITRUST LITIGATION MDL No. 2819-NG-LB (E.D.N.Y.)

The Firm is Co-Lead Counsel for End-Payer Plaintiffs in an antitrust class action filed against Allergan, Inc. for an alleged scheme to delay generic competition to Allergan’s blockbuster Restasis drug (used primarily for the treatment of chronic dry eyes). The Firm brought suit on behalf of its client and named class representative, the Self-Insured Schools of California, a Joint Powers Authority providing health benefits to over 300,000 public school district employees and their family members. Plaintiffs allege that Allergan unlawfully extended its monopoly in the market for Restasis through a series of fraudulent and anticompetitive acts. The suit is currently part of a multidistrict litigation pending in the United States District Court for the Eastern District of New York. Class certification has been granted. A late 2021 trial date is likely.

IN RE: XYREM (SODIUM OXYBATE) ANTITRUST LITIGATION No. 20-MD-02966-LHK (S.D.N.Y.)

The Firm represents Plaintiff, purchaser Self-Insured Schools of California, in a multi-district litigation antitrust suit in which it serves on the Plaintiffs’ Steering Committee. Plaintiff and a potential class of other purchasers are insurers, health and welfare plans, and consumers seeking relief from indirectly paying for and/or providing reimbursement for purchases of Xyrem (an oral narcolepsy drug) at supra-competitive prices. Facing the impact of competitive market forces, Defendant Jazz (Xyrem manufacturer) allegedly turned to an anticompetitive scheme to delay generic entry and maintain its monopoly. Plaintiffs seek class certification, damages, and other injunctive and equitable relief.

IN RE LIDODERM ANTITRUST LITIGATION No. 3:14-md-02521-WHO (N.D. Cal.)

The Firm served as End-Payors’ Liaison Counsel in a class action lawsuit brought by indirect purchasers of Lidoderm against Endo Pharmaceuticals, Teikoku, and Actavis Inc. Plaintiffs claimed that Defendants entered into an illegal reverse payment agreement in which Endo provided nearly $100 million worth of branded Lidoderm and additional consideration to Actavis to keep generic lidocaine patches off the market. Plaintiffs alleged that the agreement delayed generic competition and caused Plaintiffs to pay higher prices. In 2017, the Court granted Plaintiffs’ motion to certify a class of Lidoderm End- Payors. The case settled in early 2018, shortly before trial, for $105 million. saverilawfirm.com 10 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 112 of 228 PageID# 11307

CASE PROFILES JOSEPH SAVER! LAW FIRM

IN RE OPANA ER ANTITRUST LITIGATION No. 1:14-cv-10150 (N.D. Ill.)

The Firm represents Plaintiffs in a proposed class action brought by indirect purchasers against brand and generic manufacturers of Opana ER. Plaintiffs allege that Defendants Endo Pharmaceuticals Inc. and Impax Laboratories entered an illegal “pay-for-delay” or reverse payment agreement whereby Endo provided Impax over $100 million in cash, as well as other valuable consideration, in exchange for Impax’s promise to keep generic versions of Opana ER off the market. Plaintiffs allege that this prevented generic competition and resulted in higher prices.

MEIJER V. ABBOTT LABORATORIES Nos. 4:07-cv-5470, 4:07-cv-5702, 4:07-cv-5985 (N.D. Cal.)

Mr. Saveri served as Liaison Counsel on behalf of the class of Direct Purchaser Plaintiffs in the Norvir Antitrust Litigation. The case involved claims under Section One and Section Two of the Sherman Act in connection with the sale, marketing, and pricing of the bundled drugs Norvir and Kaletra by Abbott Laboratories. Mr. Saveri participated in all phases of the litigation, including trial. Among other highlights, his work during jury selection of the case resulted in the landmark decision by the Ninth Circuit Court of Appeals in SmithKline Beecham Corp. v. Abbott Laboratories, 740 F.3d 471 (9th Cir. 2014), confirming that equal protection prohibits discrimination based on sexual orientation in jury selection and that the Supreme Court’s decision in Batson v. Kentucky, 476 U.S. 79 (1986), applies in civil cases. Following jury selection, the Direct Purchasers settled their claims in full for $52 million.

CUNG LE V. ZUFFA, LLC No. 2:15-cv-01045-RFB-PAL (D. Nev.)

The Firm is Co-Lead Counsel for Professional Mixed Martial Arts (MMA) Fighters in a class action against MMA promoter Ultimate Fighting Championship (“UFC”) and its parent company Zuffa LLC. Plaintiffs allege that the UFC illegally acquired and maintained monopoly power in the market for promoting Professional MMA Bouts and monopsony power in the market for Professional MMA Fighters’ Services and used that monopoly and monopsony power to suppress compensation for MMA fighters who fought for the UFC. The Court denied Defendants’ motion to dismiss. In December 2020, the Court certified the class.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

JONES V. VARSITY BRANDS No. 2:20-cv-02892 (W.D. Tenn.)

The Firm represents a class of competitive cheer families against Varsity Brands, LLC; Varsity Spirit, LLC; Varsity Spirit Fashion & Supplies, LLC; U.S. All Star Federation, Inc.; and other co- conspirators. Plaintiffs allege Defendants have abused Varsity’s market power to raise, fix, and stabilize the prices charged and associated with competitive cheer. As a result, cheer athletes, together with their parents, friends, and families, have been overcharged by the Defendants, who have obtained millions of dollars in supracompetitive illegal profits.

GIORDANO V. SAKS INCORPORATED No. 1:20-cv-00833-MKB-CLP (E.D.N.Y.)

The Firm is Co-Lead Class Counsel in a “no-poach” class action, alleging that Defendants Saks Incorporated; Saks & Company LLC; Saks Fifth Avenue LLC; Louis Vuitton USA Inc.; Fendi North America, Inc.; Loro Piana & C. Inc.; Gucci America, Inc.; Prada USA Corp.; and Brunello Cucinelli, USA, Inc. agreed not to hire one another’s luxury retail employees. Plaintiffs are former sales professionals who sought employment opportunities with other Defendants. Plaintiffs allege the illegal agreements restrain competition for luxury retail employees working for Defendants. Plaintiffs seek damages and injunctive relief.

JESSICA ROBINSON V. JACKSON HEWITT, INC. AND TAX SERVICES OF AMERICA, INC. No. 2:19-cv-9066 (D. N.J.)

The Firm is Interim Co-Lead Counsel for Plaintiffs in an antitrust class action against Defendants Jackson Hewitt, Inc. and Tax Services of America, Inc. Plaintiffs are individuals who work or have worked for Jackson Hewitt, a tax preparation services provider and franchisor, and for franchise locations of Jackson Hewitt. From approximately January 2000 through December 2018, Defendants and other co-conspirators agreed not to compete for employees and potential employees, including agreements not to solicit, recruit, or hire without prior approval each other’s personnel. Plaintiffs seek injunctive relief and recovery of damages arising from Defendants’ violations of Section 1 of the Sherman Act.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

JANE DOE V. YOUTUBE, INC. No. 20-CIV-04023 (San Mateo County Sup. Ct.)

The Firm represents Plaintiff and a nation-wide class of content moderators. The suit alleges that content moderators responsible for viewing and removing offensive and disturbing videos and images posted by YouTube users are suffering from psychological trauma and post-traumatic stress disorder, and are not being protected properly by the social media company. Plaintiffs seek workplace improvements and compensation for exposure to objectionable content on YouTube’s platform.

IN RE 2021 SHORT SQUEEZE TRADING LITIGATION No. 3:21-cv-00781 (N.D. Cal.), No. 1:21-md—02989 (S.D. Fla.)

The Firm has filed suit on behalf of a proposed class of retail investors against Robinhood Markets, Inc. and various brokerages, investment funds, and other co-conspirators who allegedly entered into an illegal scheme designed to shield themselves from massive industry losses they had incurred due to their highly speculative short selling strategies. Plaintiffs allege that they and other retail investors continue to be injured due to a large, overarching conspiracy among Defendants to stop them from buying stocks in open and fair public securities markets. Plaintiffs seek damages recovery and injunctive relief. In April 2021, this suit and several similar ones were centralized and moved to the Southern District of Florida.

IN RE DENTAL SUPPLIES ANTITRUST LITIGATION No. 1:16-cv-00696-BMC-GRB (E.D.N.Y.)

The Firm serves as a member of the Plaintiffs’ Executive Committee in a class action of direct purchasers against the primary dental product distributors in the United States. Plaintiffs allege that Patterson Companies, Inc., Henry Schein, Inc., and Benco Dental Supply Company illegally boycotted competitor dental product distributors to maintain and extend their dominant position in the market for dental supplies and equipment. As a result, Plaintiffs (and similarly situated dental practices) paid inflated prices for important dental products, including imaging devices, dental chairs, high-tech equipment, sterilization products, and other related materials. Final judgment and a Court order granting an $80 million settlement was reached in 2019.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

IN RE EPIPEN MARKETING, SALES PRACTICES, AND ANTITRUST LITIGATION MDL No. 2785, No. 17-md-02785-DDC-TJJ (D. Kan)

The Firm is on the Plaintiffs’ Steering Committee in this multidistrict litigation case alleging that Mylan, Pfizer, and their related companies engaged in federal and state antitrust violations, RICO violations, and violations of state consumer protection laws with regard to the EpiPen autoinjector drug device. Defendants raised their prices by hundreds of percent and forced consumers to buy two EpiPens at a time instead of one in order to maximize their profits. In August 2018, the Court denied Defendants’ motions to dismiss as to the vast majority of Plaintiffs’ claims. Discovery is proceeding. Trial is anticipated late 2021-early 2022.

PASKENTA BAND OF NOMLAKI INDIANS V. CROSBY No. 2:15-cv-00538-MCE-CMK (E.D. Cal.)

The Firm is Co-Lead Counsel in a suit in which it represents the Paskenta Band of Nomlaki Indians pursuing the recovery of tens of millions of dollars converted by former tribal officials. The Tribe brings civil RICO and various state law claims alleging that these formal tribal officials—with a number of associated individuals, banks, and benefit providers—operated a RICO Enterprise that facilitated the looting of tribal moneys. These former tribal officials spent the Tribe’s funds on luxury homes, expensive cars, private jet travel, exclusive entertainment and vacations, and their personal expenses.

IN RE GENERIC PHARMACEUTICALS PRICING ANTITRUST LITIGATION No. 2:16-md-02724-CMR (E.D. Pa.)

The Firm is on the Plaintiffs’ Steering Committee for End-Payor Plaintiffs and its client, the Self-Insured Schools of California, and similarly situated U.S. consumers and insurers, against dozens of generic drug manufacturers in this broad multidistrict litigation. The antitrust suit charges the Defendants with conspiring to fix and raise prices for over 30 different generic pharmaceutical drugs, forcing consumers to pay inflated prices for medication to treat a wide variety of illnesses and diseases.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

SPRADLING V. SURGICAL CARE AFFILIATES, LLC No. 21-cv-01324 (N.D. Ill.)

The Firm represents Plaintiff Allen Spradling and a potential Class of senior-level employees in an antitrust suit filed against Defendants Surgical Care Affiliates, United Surgical Partners International, and at least one other unnamed healthcare service provider. Plaintiffs allege Defendants entered into “no-poach” agreements not to compete for senior-level employees in the United States. These agreements allegedly accomplished their purpose by reducing competition for Defendants’ senior-level employees and suppressing Defendants’ senior-level employees’ compensation below competitive levels. They also denied their senior-level employees access to job opportunities, restricted their mobility, and deprived them of significant information that they could have used to negotiate for better compensation and employment terms. Plaintiffs seek to damages recovery and injunctive relief to prevent Defendants from retaining the benefits of their alleged antitrust violations.

IN RE JUUL LABS, INC. ANTITRUST LITIGATION 3:20-cv-02345-WHO (N.D. Cal.)

The Firm is Interim Lead Counsel for Direct Purchaser Plaintiffs in e- cigarette antitrust lawsuits against Altria Group, Inc. (Altria) and Juul Labs, Inc. (JLI) on behalf of individuals and businesses who purchased JUUL e-cigarette devices directly from JLI. Plaintiffs and the Class seek damages recovery for violations of the Sherman and Clayton Acts. The e-cigarette antitrust claims stem from an allegedly anticompetitive agreement between Altria and JLI, whereby Altria agreed to acquire an ownership interest in JLI in exchange for over $12 billion. Altria also allegedly agreed not to compete with JLI and to provide JLI valuable retail shelf space in the e-cigarette market. Through this agreement, JLI was able to maintain its dominance in the e-cigarette market and earn monopoly profits. Altria then shared these profits through its ownership stake in JLI.

FOND DU LAC BUMPER EXCHANGE INC. V. JUI LI ENTERPRISE COMPANY LTD. No. 2:09-cv-00852-LA (E.D. Wisc.)

The Firm represents a class of auto parts distributors who allege that Taiwanese manufacturers of aftermarket sheet metal auto parts colluded to artificially raise prices and eliminate competition. The Court has granted final approval to settlements by two Defendants totaling $25 million and has granted Plaintiffs’ motion for class certification.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

CHIP TECH, LTD. V. AVX CORP. No. 3:15-cv-03820-JD (N.D. Cal.)

The Firm is counsel for a putative class of direct purchasers of resistors used in electronic devices. Plaintiffs allege that Defendants formed a cartel and conspired to fix, raise, and stabilize prices in the multi-billion-dollar market for resistors.

MICROSOFT PRIVATE ANTITRUST LITIGATION Representing businesses and consumers, Mr. Saveri prosecuted multiple private antitrust cases against Microsoft Corporation in state courts across the country, including Florida, New York, North Carolina, and Tennessee. Plaintiffs alleged that Microsoft engaged in anticompetitive conduct and/or violated state deceptive and unfair business practices statutes to harm competition and monopolize the markets for Intel-compatible, personal computer operating system software, as well as word processing and spreadsheet software. In 2006, the New York Supreme Court granted final approval to a settlement that made available up to $350 million in benefits for New York businesses and consumers. In 2004, the Court in the North Carolina action granted final approval to a settlement valued at over $89 million, and the Court in the Tennessee action granted final approval to a $64 million settlement. In 2003, in the Florida Microsoft litigation, the Court granted final approval to a $202 million settlement, one of the largest antitrust settlements in Florida history. Mr. Saveri served as Co-Lead Counsel in the New York, North Carolina, and Tennessee cases, and held leadership roles in the Florida case.

IN RE LUPRON MARKETING AND SALES PRACTICES LITIGATION MDL No. 1430 (D. Mass.)

In 2005, the Court approved a settlement of a class action brought by patients, insurance companies, and health and welfare benefit plans that paid for Lupron, a prescription drug used to treat prostate cancer, endometriosis, and precocious puberty. The settlement requires the Defendants Abbott Laboratories, Takeda Pharmaceutical Company Limited, and TAP Pharmaceuticals to pay $150 million to persons or entities that paid for Lupron from January 1, 1985 through March 31, 2005. Plaintiffs charged that the Defendants conspired to overstate the drug’s average wholesale price, which resulted in Plaintiffs paying more for Lupron than they should have paid. Mr. Saveri served as Co- Lead Plaintiffs’ Counsel. saverilawfirm.com 16 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 118 of 228 PageID# 11313

CASE PROFILES JOSEPH SAVER! LAW FIRM

IN RE BUSPIRONE ANTITRUST LITIGATION MDL No. 1413 (S.D.N.Y.)

In 2003, Mr. Saveri obtained a $90 million cash settlement for individual consumers, consumer organizations, and third-party payors that purchased BuSpar, a drug prescribed to alleviate symptoms of anxiety. Plaintiffs alleged that Bristol-Myers Squibb Co. (“BMS”), Danbury Pharmacal, Inc., Watson Pharmaceuticals, Inc., and Watson Pharma, Inc. entered into an unlawful agreement in restraint of trade under which BMS paid a potential generic manufacturer of BuSpar to drop its challenge to BMS’s patent and refrain from entering the market.

CALIFORNIA VITAMIN CASES J.C.C.P. No. 4076 (San Francisco County Sup. Ct.)

Mr. Saveri served as Co-Liaison Counsel and Co-Chairman of the Plaintiffs’ Executive Committee on behalf of a class of California indirect vitamin purchasers (in every level of the chain of distribution) against vitamin manufacturers alleged to have engaged in price fixing of particular vitamins. In 2002, the Court granted final approval of a $96 million settlement with certain vitamin manufacturers. In 2006, the Court granted final approval to over $8.8 million in additional settlements.

PHARMACEUTICAL CASES I, II, AND III J.C.C.P. Nos. 2969, 2971, and 2972 (San Francisco County Sup. Ct.)

Mr. Saveri served as Co-Lead and Co-Liaison Counsel representing a certified class of indirect purchasers (consumers) on claims against the major pharmaceutical manufacturers for violations of the Cartwright Act and the Unfair Competition Act. The class alleged that Defendants unlawfully fixed discriminatory prices on prescription drugs to retail pharmacists in comparison with the prices charged to certain favored purchasers, including HMOs and mail order houses. In 1999, the Court approved a settlement providing $148 million in free, brand-name prescription drugs to health agencies that serve California’s poor and uninsured. In 2001, the Court approved a settlement with the remaining Defendants in the case, which provided an additional $23 million in free, brand-name prescription drugs to these agencies.

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CASE PROFILES JOSEPH SAVER! LAW FIRM

IN RE BRAND NAME PRESCRIPTION DRUGS MDL No. 997 (N.D. Ill.)

Mr. Saveri served as Class Counsel for a class of tens of thousands of retail pharmacies against the leading pharmaceutical manufacturers and wholesalers of brand name prescription drugs for alleged price-fixing from 1989 to 1995 in violation of the federal antitrust laws. Class Plaintiffs charged that Defendants engaged in price discrimination against retail pharmacies by denying those discounts provided to hospitals, health maintenance organizations, and nursing homes. In 1996 and 1998, the Court approved settlements with certain manufacturers totaling $723 million.

IN RE ELECTRICAL CARBON PRODUCTS ANTITRUST LITIGATION MDL No. 1514 (D.N.J.)

Mr. Saveri represented the City and County of San Francisco and a class of direct purchasers of carbon brushes and carbon collectors on claims that producers fixed the price of carbon brushes and carbon collectors in violation of the Sherman Act.

IN RE TRAVEL AGENCY COMMISSION ANTITRUST LITIGATION MDL No. 1058 (D. Minn.)

Mr. Saveri served as Co-Lead Counsel for a certified class of U.S. travel agents on claims against the major U.S. air carriers, who allegedly violated the federal antitrust laws by fixing the commissions paid to travel agents. In 1997, the Court approved an $82 million settlement.

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Judicial Praise for the Joseph Saveri Law Firm

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JUDICIAL PRAISE JOSEPH SAVER! LAW FIRM

“Through my extensive observations of counsel, I am assured that they are well qualified to litigate this class action…. I have no hesitation that these lawyers will ‘fairly and adequately represent the interests of the class.’”

JUDGE NINA GERSHON, In Re Restasis (Cyclosporine Opthalmic Emulsion) Antitrust Litigation, Master File No. 1:17-cv-06684 (E.D.N.Y. 2020)

“The MDL litigation has been hard-fought by both sides and required an enormous amount of work to collect evidence in the United States and several overseas countries, bring and defend complex motions, and prepare a sprawling case for a jury trial. Class Counsel prosecuted the case with skill and vigor, and achieved strongly positive results. The Court also appreciated the professionalism and spirit of cooperation that Class Counsel brought to the proceedings.”

JUDGE JAMES DONATO, In re Capacitors Antitrust Litigation, Master File No. 3:14-cv-03264-JD (N.D. Cal. 2020)

“The docket and the procedural history in this case demonstrate Counsel’s expertise and the Direct Purchaser Plaintiffs’ success to date. Counsel have done much to effectively prosecute the Class’s claims, and to do so efficiently. Counsel have not come by their success in this litigation easily. Defendants—including the Settling Defendants—have hired the best antitrust counsel money can buy to defend them against the Direct Purchaser Plaintiffs’ Sherman Act claims.”

JUDGE JAMES DONATO, In re Capacitors Antitrust Litigation, Master File No. 3:14-cv-03264-JD (N.D. Cal. 2017)

“Direct Purchaser Plaintiffs’ Counsel vigorously and effectively pursued the Direct Purchasers’ claims. These efforts included factual investigation, drafting complaints, briefing and arguing motions to dismiss and for summary judgment, reviewing and analyzing documents, interviewing witnesses and taking dozens of depositions in the United States and abroad, negotiating the terms of the settlements, and preparing the settlement documents.”

JUDGE MARIANNE O. BATTANI, In re Automotive Parts Antitrust Litigation/In re Wire Harness Cases, Master File No. 12-md-02311 (E.D. Mich. 2017) saverilawfirm.com 20 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 122 of 228 PageID# 11317

JUDICIAL PRAISE JOSEPH SAVER! LAW FIRM

“The Joseph Saveri Law Firm invested a great deal of time and effort to investigate and develop the potential claims in this action, and it filed the first complaint in this case as a result. . . . The Joseph Saveri Law Firm also has the support of many of the plaintiffs’ counsel, which the Court does find to be a significant factor in the Saveri Firm’s favor [for appointment to Interim Lead Class Counsel].”

JUDGE JAMES DONATO, In re Capacitors Antitrust Litigation, Master File No. 3:14-cv-03264-JD (N.D. Cal. 2014)

“As noted by the Plaintiffs: ‘Since their initial appointment, [the Joseph Saveri Law Firm and other interim co-lead and liaison counsel, and the Plaintiffs’ Executive Committee] . . . have devoted substantial time and resources to this case, including complex legal matters on a variety of motions, case management, discovery planning, and extensive meetings and conferrals with Defendants regarding ongoing discovery. Moreover, proposed Class Counsel have demonstrated their extensive experience and expertise prosecuting antitrust, class action, and complex civil litigation cases and have successfully litigated antitrust class actions and other similar cases in courts throughout the United States.’ Defendants do not object or disagree with the Plaintiffs' characterization of their representation. This Court has reviewed the [Federal Rules of Civil Procedure] Rule 23(g)(1) requirements, and concludes that Plaintiffs' proposed co-lead counsel are well qualified to represent the Class in this case.”

JUDGE RICHARD D. BENNETT, In re Titanium Dioxide Antitrust Litigation, 284 F.R.D. 328 (D. Md. 2012), amended, 962 F. Supp. 2d 840 (D. Md. 2013)

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OUR TEAM

The Firm’s attorneys are well-regarded for their integrity, experience, and success in all phases of litigation. They have received multiple awards from the American Antitrust Institute, Chambers and Partners, Martindale Hubbell, The Legal 500, Who’s Who Legal, and Super Lawyers. Partners Joseph Saveri and Steven Williams are recognized as two of the country’s top lawyers and leaders in federal antitrust and class action litigation.

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Joseph R. Saveri

Mr. Saveri began his career performing general litigation work at the San Francisco law firm of McCutchen, Doyle, Brown & Enersen. In 1992, he joined the plaintiffs’ firm Lieff Cabraser Heimann & Bernstein (“LCHB”), where he was the firm’s Managing Partner and established its antitrust and intellectual property practice, which was recognized in 2012 as one of the top five practice groups in California. He left LCHB in May 2012 to start his own firm.

Mr. Saveri has performed virtually every aspect of complex and class action litigation, including factual and economic analysis of market conditions and pricing practices, drafting of pleadings, law and motion matters, organizing e- discovery, creating a discovery plan, administering and directing on-line review of documents requiring coordination of dozens of lawyers fluent in English and foreign languages, propounding written discovery, taking and defending percipient and expert witness depositions, organizing the factual record, PRACTICE AREAS Antitrust briefing and arguing summary judgment, and leading trial and appellate work. Class Actions Complex Business Disputes Commercial Litigation From 2010 through 2013, Mr. Saveri was chosen to serve as a Lawyer Intellectual Property Representative for the United States District Court for the Northern District of Qui Tam and Whistleblower California and the Ninth Circuit Court of Appeals. He has served and serves on ADMISSIONS several court committees charged with developing rules and programs State of California regarding complex litigation, e-discovery, and a variety of other matters. He US Supreme Court US Court of Appeals – Federal Circuit was chosen to serve as a member of the Northern District’s Civil Rules US Court of Appeals – First Circuit Advisory Committee from 2009-2012, the committee to establish rules and US Court of Appeals – Second Circuit procedures for expedited trials (which the Court adopted as General Order No. US Court of Appeals – Fourth Circuit US Court of Appeals – Fifth Circuit 64, “Expedited Trial Procedures”), and the committee which crafted new e- US Court of Appeals – Seventh Circuit discovery rules and procedures later adopted by the Court. He is a member of US Court of Appeals – Eighth Circuit US Court of Appeals – Ninth Circuit the American Bar Association and the Bar Association of San Francisco. US District Court – Central District of California US District Court – Eastern District of California US District Court – Northern District of California Mr. Saveri is also a frequent author of articles on antitrust and complex US District Court – Southern District of California litigation issues, and a frequent lecturer on a variety of matters, including US District Court – Northern District of Illinois US District Court – Eastern District of Michigan antitrust, complex litigation, class action practice, and discovery. He serves as US District Court – Eastern District of Wisconsin an author of California Antitrust and Unfair Competition Law, the legal treatise published by the State Bar of California’s Antitrust and Unfair Competition EDUCATION University of Virginia Law School, J.D. Section. He is also a member of the Advisory Board of the American Antitrust University of California, Berkeley, B.A. History Institute and a Fellow of the Litigation Counsel of America. In 2019, he was a and Economics (double major), with Honors speaker at the U.S. Department of Justice Antitrust Division’s public roundtable to discuss the Antitrust Criminal Penalty Enhancement & Reform Act.

f TOP RANKED • Mr. Saveri has received numerous ACCOLADES from an array of legal ~ Chambers ~ entities, including: ' USA I ••,2020,•· Benchmark Litigation: Honored as National Practice Area Star” and “Local

Joseph It Sm·cri Litigation Star” in competition/antitrust (2020)

Best Lawyers: Best Lawyers in America (2012-present) Martindale-Hubbell PREEMINENT Chambers and Partners: Band 1 (top-ranked) plaintiffs’ antitrust attorney for Peer Rated for Highest Level of Professional Excellence California and nationwide (2014-present)

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

con’t Joseph R. Saveri

Daily Journal (California): Top Plaintiff Lawyers in California (2018-present); &'k1il11;tourn11I Top 100 Lawyers in California (2016, 2018-2019); Top Antitrust Lawyers in THE2016 California (2020); CLAY Award—California Lawyer Attorney of the Year (2016); CLAY One of California’s Leading Labor & Employment Lawyers (2014) AWARDS Law 360: Titan of the Plaintiffs’ Bar for his leadership and vision in extending T1 ... 20o1o •••••••• & ....., ,_, ...... ,.,,,1.,1 .. .. the reach of antitrust cases into new areas such as pharmaceutical reverse payments and “no-poach” agreements by high-tech employers (2014)

Lawdragon: 500 Leading Plaintiff Financial Lawyers (2019-present)

Martindale-Hubbell: AV Preeminent rating—Top Rated Lawyers (2008- present)

National Law Journal: Trailblazers—Mergers & Acquisitions and Antitrust (2015)

Super Lawyers: Super Lawyers Northern California—Antitrust Litigation (2006- present); Super Lawyers Top 100 Northern California (2015-2016, 2019- present)

Who’s Who Legal: One of the top plaintiffs’ attorneys worldwide via Who’s Who Legal: Competition (publication of Who’s Who Legal and Global Competition Review (2015-present)); profiled in Thought Leaders: Competition, a publication of Who’s Who Legal (2019-present)

JOSEPH R. SAVERI 2021 Best Lawyers·

500 LEADING PLAINTIFF FINANCIAL LAWYERS

I• • I

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Steven N. Williams

In over twenty-five years of practice, Mr. Williams has handled successfully and with distinction all aspects of litigation and trial in state and federal courts and in private arbitration.

Mr. Williams has played a lead role in many of the most prominent antitrust class cases litigated in the United States over the last decade, including In re Automotive Parts Antitrust Litigation, In re Static Random Access Memory Litigation, Precision Associates v. Panalpina World Transport, and In re Transpacific Air Transportation Litigation. Over the last decade he has been named lead or co-lead counsel in more antitrust cases than perhaps any other attorney in the United States. He has helped recover more than $2 billion and has been responsible for new law including ground-breaking decisions narrowing the scope of the Filed Rate Doctrine and permitting civil damage claims in E. & J. Gallo Winery v. EnCana Corp., 503 F.3d 1027 (2007) and PRACTICE AREAS Wortman v. All Nippon Airways, 854 F.3d 606 (2017), and a ruling that Antitrust “umbrella damages” are available under California state law. County of San Class Actions Commercial Litigation Mateo v. CSL, Ltd., 2014 U.S. Dist. LEXIS 116342 (N.D. Cal. Aug. 20, 2014). Consumer Protection Qui Tam Mr. Williams—previously a long-time partner at Cotchett, Pitre & McCarthy, ADMISSIONS LLP—practices in the fields of litigation, trial, and client counseling, with an State of California State of New Jersey emphasis on representation of civil plaintiffs in antitrust matters. He has served State of New York in leadership positions in more than a dozen antitrust class cases throughout US Supreme Court the United States. During his career, he has represented claimants in cases US Court of Appeals – Second Circuit US Court of Appeals – Third Circuit involving memory chips, pharmaceuticals, air passenger transportation, air US Court of Appeals – Fifth Circuit cargo transportation, cathode ray tubes, capacitors, resistors, flash memory, US Court of Appeals – Sixth Circuit US Court of Appeals – Ninth Circuit lithium-ion batteries, financial products and services, poultry, and water. He has US Court of Appeals – District of Columbia Circuit been appointed to represent both classes and individuals. In non-class cases US District Court – Eastern District of California he has represented the Chief Justice of California, the Judicial Council of US District Court – Central District of California US District Court – Northern District of California California, Consumers Union of United States, Inc., the United Farm Workers, US District Court – Southern District of California Dolores Huerta, public pension funds, private investment funds, many cities US District Court – Eastern District of Michigan and counties of California, public utilities including water districts, and individual US District Court – District of New Jersey US District Court – Eastern District of New York consumers. US District Court – Southern District of New York

EDUCATION Among other cases, Mr. Williams currently represents a Plaintiff Class of Fordham University School of Law, J.D. content moderators, responsible for viewing and removing offensive and New York University, B.A., Russian & Slavic Studies disturbing content from Facebook users, who are allegedly suffering from PTSD and other trauma-related injuries because they were not being properly protected by the social media company. In 2020, the Class reached a ground- breaking preliminary settlement for $52 million and workplace improvements.

TOP RANKED • f Mr. Williams has written and lectured on various topics including antitrust, ~ Chambers ~ multidistrict litigation, complex litigation, e-discovery, MTBE litigation, regulatory ' s • developments in environmental law, contractual issues in environmental ••,2020,•· cleanups, and habeas corpus. He has spoken at many venues, including the American Bar Association Antitrust Section Spring Meeting, the California State Bar Antitrust, UCL and Privacy Section, the New York State Bar Association Antitrust Section, and yearly presentations on civil discovery topics to the M,111 i nd1lc-Hubbcl I Consumer Attorneys of California. PREEMINENT P(,,,c, r R,,tC'd ror H'Qh(>St Lc....c, I o!Prof,r,!.•,,onnl E:,,.cr;, lk'ncc- Mr. Williams is the author or co-author of several publications, including: “A Practitioner’s Perspective: Why The Supreme Court Should Not Overturn Illinois Brick in Apple v. Pepper,” Competition, The Journal of the Antitrust and Unfair Competition Law Section of the California Lawyers Association; “Should United States Courts Defer to Foreign Governments?,” Chambers and saverilawfirm.com 25 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 127 of 228 PageID# 11322

OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

con’t Steven N. Williams

Partners’s Cartels 2019 global practice guide; “‘Apple v. Pepper’ Will Enhance Private Antitrust Enforcement by Confirming Bright-Line Rule of ‘Illinois Brick,’” May 2019 The Recorder; “‘Pepper’ as a Back Door to ‘Illinois Brick’ (and ‘ARC

AMERICAN America’)?” and “Should ‘Hanover Shoe’ and ‘Illinois Brick’ Be Discarded?,” ANTITRUS August 2018 The Recorder; Antitrust Law Developments (Eighth), American INSTITUTE Bar Association; “Federal and State Class Antitrust Actions Should Not Be Tried in a Single Trial,” The Journal of the Antitrust and Unfair Competition Law Section of the State Bar of California, Fall 2014; “Recoveries for Violations of Federal and California Antitrust Statutes Should Not Be Apportioned," Competition, Antitrust and Unfair Competition Law Section, California State Bar, Fall 2014; “Antitrust Whistleblowers Get Clarity,” Los Angeles and San Francisco Daily Journal, 2013; “Courts Rein in the Cost of E-Discovery When Lawyers and Their Clients Won’t,” California Lawyer, April 2012; and California’s 2009 E-Discovery Laws, Text and Analysis, LexisNexis 2009.

Mr. Williams was appointed by the Consumer Attorneys of California as a member of the California Discovery Subcommittee for revision of California discovery rules and statutes relating to e-discovery and electronically stored information, 2007-2008. He is currently in leadership for the American Bar Association Antitrust Section and is a member of the International Cartel Task Force and the Executive Committee of the Committee to Support the Antitrust Laws. He is an advisor to the Executive Committee of the California Lawyers Association Section on Antitrust, Unfair Competition Law, and Privacy Law, and was chair of the 2017 Golden State Antitrust Institute. He is a Board Member of 500 Public Justice and past Chairman of the Board of Community Gatepath, an LEADING PLAINTIFF FINANCIAL organization dedicated to serving the needs of developmentally disabled LAWYERS children and adults. He received the Justice & Diversity Center (JDC) of the Bar Association of San Francisco’s Federal Pro Bono Project 2020 Crystal Award I I • • for “Outstanding Volunteer of the Year,” and in 2018, the JDC recognized him as an “Outstanding Volunteer.”

Mr. Williams has received numerous professional ACCOLADES, including:

American Antitrust Institute: Honoree for Antitrust Enforcement Awards for “Outstanding Antitrust Litigation Achievement in Private Law Practice” for his key role in In re Automotive Parts Antitrust Litigation (2019)

Benchmark Litigation: Honored as National Practice Area Star” and “Local Litigation Star” in competition/antitrust (2020)

Best Lawyers: Best Lawyers in America (2020)

Chambers and Partners: Band 1 or Band 2 plaintiffs’ antitrust attorney for California (2015-present) and nationwide (2017-present)

Daily Journal (California): Top Plaintiff Lawyers in California (2018-present); Top Antitrust Lawyers in California (2020)

Lawdragon: 500 Leading Plaintiff Financial Lawyers (2019-present)

Martindale-Hubbell: AV Preeminent rating—Top Rated Lawyers (2002- present)

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

con’t Steven N. Williams

Super Lawyers: Super Lawyers Northern California—Antitrust Litigation Super Lawyer (2005-present); Super Lawyers Top 100 Northern California (2016-

STEVEN N. WILLIAMS 2021 present)

Best Lawyers· Who’s Who Legal: One of the top plaintiffs’ attorneys worldwide via Who’s Who Legal: Competition (publication of Who’s Who Legal and Global Competition Review (2014-present)); profiled in Thought Leaders: Competition, a publication of Who’s Who Legal (2019-present)

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Katharine Malone

Ms. Malone joined the Firm in 2020. Her career practice has focused on commercial and class action litigation, representing both plaintiffs and defendants in matters related to information privacy, contract, fraud, breach of fiduciary duties, and employee mobility issues. She has experience litigating in state and federal trial and appellate courts and state supreme courts.

Ms. Malone has a well-established, successful track record as an associate at two San Francisco law firms. She has litigated and advised clients in complex commercial matters—including business disputes, consumer litigation, and employment matters—for public and private companies, from pre-litigation counseling through trial and appeals. She has extensive experience in all phases of motion practice, discovery, and trial procedure, up to and including preparing testifying witnesses for direct and cross-examination at trial. Among

PRACTICE AREAS her many highlights, she briefed and argued Lil’ Man in the Boat v. Auk Ta Class Action Shaa before the United States Court of Appeals (Ninth Circuit) to uphold a Complex Business Disputes district court dismissal of a contract dispute, prevailing on both procedural and substantive grounds for a corporate client. ADMISSIONS State of California US Court of Appeals – Ninth Circuit Ms. Malone regularly writes and comments on various legal affairs. Her US District Court – Northern District of California publications include: “Welcome to New York It’s Been Waiting for You . . . But Is Your Business Ready for the New York SHIELD Act?,” CPO Magazine (April EDUCATION 1, 2020); “Data Privacy: The Current Legal Landscape 2018 Reviewed,” University of California, Hastings College of the Law, J.D.; CALI Award, Cyberlaw; Albert G. Troutman Sanders Insights (January 15, 2019); “Did the General Contractor on Evans Scholarship in Enterprise Award the Death Star Have to Build the Second Death Star for Free?,” The Legal Geeks (February 2, 2018); and “Think Twice Before Denying Requests for George Washington University, B.A., Political Science, Journalism; National Merit Scholar; Admissions,” California Daily Journal (September 24, 2015). Atlantic-10 Conference Student-Athlete Honor Roll (varsity crew team) Prior to her career as an associate, Ms. Malone was an associate legal editor for the California Daily Journal. During law school at Hastings College of the Law, she was editor-in-chief of the Hastings Communications & Entertainment Law Journal, where she authored “Parody or Identity Theft: The High-Wire Act of Digital Doppelgangers in California,” 34 Hastings Comm. & Ent. L.J. 275.

Ms. Malone is a member of the Bar Association of San Francisco.

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Ryan Louie Manuel

Mr. Manuel specializes in antitrust and class action litigation, and approaches his practice with compassion, perseverance and hard work. He has experience in all stages of litigation, including propounding and responding to discovery requests, coordinating and conducting document discovery, taking depositions, and successfully completing trial-related tasks.

Mr. Manuel’s professional qualifications are exemplified by his invaluable work on the Firm’s Capacitors trial. He is heavily involved in providing essential support and preparation for trial, including drafting the exhibit list, assisting in preparing trial witnesses, and daily management of trial logistics.

Prior to joining the Firm, Mr. Manuel was a post-bar law clerk for a boutique San Mateo, California litigation firm. He researched legal matters relating to construction defects, contract formation, and defenses to the enforceability of PRACTICE AREAS Antitrust a contract. He assisted counsel by preparing law and motion legal Class Action memoranda used by counsel in drafting an opposition to demurrer, settlement demand letters, and motions for summary judgment. He also assisted ADMISSIONS counsel with case management and strategy, and meeting day-to-day case State of California deadlines. EDUCATION University of San Francisco School of Law, J.D., Student Bar Association Award As a former intern for the California Public Utilities Commission (CPUC), Mr. Manuel researched legal and legislative law as part of the CPUC’s Public University of California Santa Barbara, B.S., Advocates Office branch, and addressed the CPUC’s responsibilities in Political Science and Global Studiesand Minor in Asian American Studies implementing Time of Use rate changes and applicability and enforcement of bill protection. He also prepared memoranda on the enforcement of a LANGUAGES California judgment upon an out-of-state defendant located in New York and Tagalog (native) French (conversational) Florida, and researched and prepared internal memos pertaining to the CPUC’s investigatory authority over non-parties and/or non-utility actors who transact business with a public utility affecting rate-payer’s interests.

Mr. Manuel is a former judicial extern for the San Francisco County Superior Court probate department, where he drafted bench memos addressing diverse procedural and substantive matters, reviewed and summarized documentary evidence, and observed court proceedings.

While at the University of San Francisco School of Law, Mr. Manuel participated in the Intense Advocacy Program and was a legal clinician- student attorney at its Internet and Intellectual Property Clinic. He was the symposium editor of the University of San Francisco Law Review and was president of the Asian Pacific American Law Student Association, Co-Chair President of the Pilipino American Law Society, and Media Chair for the Environmental Law Student and Alumni Society.

Prior to law school, Mr. Manuel was a case administrator for a prestigious Bay Area law firm, at which he monitored, supported and managed case docket and staffing for various cases.

Mr. Manuel is a member of the Filipino Bar Association of Northern California, Bay Area Lawyers for Individual Freedom, Asian American Bar Association, Gay Asian Pacific Alliance (GAPA), and National Filipino American Lawyers Association (NFALA). saverilawfirm.com 29 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 131 of 228 PageID# 11326

OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Kyle Quackenbush

Mr. Quackenbush specializes in class actions and other complex civil litigation, with a focus on antitrust. He has participated in all stages of litigation, including drafting pleadings, coordinating document discovery, taking depositions, filing dispositive motions, and attending trials. He is particularly interested in the interplay between antitrust and intellectual property law in the pharmaceutical industry as well as market concentration within the payor and provider networks in the United States’ healthcare industry.

Mr. Quackenbush currently volunteers with the Federal Pro Bono Project of the Bar Association of San Francisco. He represents a Plaintiff who alleges employees at Salinas Valley State Prison were deliberately indifferent to the Plaintiff’s serious medical needs, in violation of the Eighth Amendment.

PRACTICE AREAS During law school, Mr. Quackenbush was a Summer Honors Legal Intern at the Antitrust Federal Trade Commission’s San Francisco office, and a Legal Extern at the Consumer Protection Washington State Attorney General’s Office. While at the Federal Trade ADMISSIONS Commission, he co-authored “The Efficiencies Defenestration, Are Regulators State of California Throwing Valid Healthcare Efficiencies Out The Window?” Competition, The US Court of Appeals – Second Circuit Journal of the Antitrust and Unfair Competition Law Section of the California US Court of Appeals – Ninth Circuit US District Court – Northern District of California Lawyers Association, Winter 2017-18. US District Court – Southern District of California US District Court – Northern District of California Mr. Quackenbush also volunteered with the Immigrant Families Advocacy EDUCATION Project and the Street Youth Legal Advocates of Washington, and helped University of Washington School of Law, J.D. immigrants apply for citizenship at Citizenship Workshops.

Santa Clara University, B.S., Political Science; B.A., Spanish Studies Mr. Quackenbush was named a Northern California “Rising Star” in 2020 by Thomson Reuters’s Super Lawyers publication. He is a member of the LANGUAGES Spanish (conversational) American Bar Association and the Bar Association of San Francisco. He also actively participates in the Barristers Association of San Francisco, working with the pro bono committee to provide information and resources to lawyers

RATED BY who are in their first 10 years of practice. --Rising Stars Kyle Quackenbush

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Kevin Rayhill

Mr. Rayhill specializes in antitrust class actions and other complex litigation. He advocates for the rights of workers, taking on some of the biggest employers in professional sports, social media, defense contracting, and luxury retail to fight for competitive wages and safe working conditions. He also fights on behalf of consumers, bringing antitrust claims against manufacturers of pharmaceuticals, laptop computers, car parts, and titanium dioxide, among others. To date, these cases have resulted in settlements exceeding $300 million.

Prior to joining the Firm, Mr. Rayhill worked as a Legal Research Attorney at the Superior Court of San Francisco (Criminal Division). While in law school, he held internships at the California Attorney General’s Office (Environment, Land Use, and Natural Resources Division) and the San Francisco City Attorney’s Office (Energy and Telecommunications Team), and an externship with Justice Stuart R. Pollak of the California Court of Appeal (First District). PRACTICE AREAS Antitrust Class Actions Mr. Rayhill is a member of the American Bar Association and the Bar Association of San Francisco. ADMISSIONS State of California US Court of Appeals – Ninth District US District Court – Central District of California US District Court – Eastern District of California US District Court – Northern District of California

EDUCATION University of California Hastings College of the Law, J.D.

Oberlin College, B.A., Religion

Berklee College of Music, Professional Diploma

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Anupama Reddy

Ms. Reddy’s practice focuses primarily on antitrust class actions alleging anticompetitive conduct such as price-fixing and monopolization. She represents businesses and individuals in complex civil litigation throughout the country. In addition to her antitrust practice, she has represented whistleblowers in qui tam matters and False Claims Act litigation against companies that have committed fraud against the government. She approaches her practice with diversity of thought, enthusiasm, and diligence.

Ms. Reddy’s professional qualifications are exemplified by her invaluable work on the Capacitors case and trial. She was heavily involved in pre-trial matters, including drafting pre-trial filings and arguing pre-trial motions. She had an active role in trial strategy, trial stagecraft, preparing and examining witnesses, and presenting evidence to the jury. Prior to trial, she drafted and argued dispositive motions in relation to summary judgment, attorney costs and fees,

PRACTICE AREAS and opt-out matters. Antitrust Qui Tam In addition to her duties for the Firm, Ms. Reddy volunteers for the Federal Pro ADMISSIONS Bono Project of the Bar Association of San Francisco. She currently represents State of California a Plaintiff in a wrongful termination matter against a multinational corporation, US District Court – Northern District of California in the Northern District of California. US District Court – Northern District of Illinois

Bar Council of India, Maharashtra & Goa Ms. Reddy graduated from Berkeley Law with a specialization in intellectual

EDUCATION property law. She was an associate editor of the Berkeley Technology Law University of California, Berkeley, School of Law, Journal, and the promoter and social co-chair of the student-led organization, LL.M. Women in Tech Law. At Symbiosis Law School in India, she was awarded the American jurisprudence equivalent award for the Law of Evidence. Symbiosis Law School, Pune, Maharashtra, India (B.B.A. LL.B), J.D. Equivalent

Institute of Company Secretaries of India, New Prior to joining the Firm, Ms. Reddy was a Law Clerk in the Antitrust Section of Delhi, India, Qualified Company Secretary the California Department of Justice, Office of the Attorney General (San Francisco), where she reviewed documents, conducted legal research, and LANGUAGES Hindi (reading and writing) drafted memoranda for investigations and litigation involving pharmaceutical Marathi (speaking) and oil and gas companies. In Mumbai, India, she was Legal Counsel for Cipla Telugu (speaking) Limited, where she specialized in contracts and mergers and acquisitions.

AMERICAN Ms. Reddy is a member of the American Bar Association and the Bar ANTITRUS Association of San Francisco. She serves by appointment on the Executive INSTITUTE Committee, and as Vice Chair of the Diversity Committee, of the California Lawyers Association, Antitrust and Privacy Section. She is a co-author of "AI and Interdependent Pricing: Combination Without Conspiracy?" Competition: The Journal of the Antitrust, UCL and Privacy Section (August 2020).

In 2020, Ms. Reddy was recognized by the American Antitrust Institute for “Outstanding Antitrust Litigation Achievement by a Young Lawyer” (for work performed in In re Capacitors Antitrust Litigation).

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OUR TEAM - ATTORNEYS JOSEPH SAVER! LAW FIRM

Christopher Young

Mr. Young specializes in antitrust and class action litigation. He approaches his practice with a diligent and creative attitude while providing clients with high- quality legal representation.

Mr. Young’s professional qualifications are exemplified by his invaluable work on the 2020 In Re Capacitors Antitrust Litigation trial. He was heavily involved in pre-trial matters, including drafting pre-trial filings and conducting pre-trial depositions. He has also been actively involved in the trial, including providing essential support and preparation for the examination of key witnesses and presenting evidence to the jury.

In addition to his duties for the Firm, Mr. Young volunteers for the Federal Pro Bono Project of the Bar Association of San Francisco. He currently represents a Plaintiff in a lawsuit asserting both federal and state causes of actions against PRACTICE AREAS Antitrust park rangers seeking civil recovery for alleged violations of several of the Class Action Plaintiff’s constitutional rights by the Defendant park rangers. The Plaintiff asserts, among other claims, violations of his Fourth and Fifth Amendment ADMISSIONS rights against unreasonable searches and seizures and the use of excessive State of California US District Court – Central District of California force. US District Court – Eastern District of California US District Court – Northern District of California US District Court – Southern District of California Before joining the Firm, Mr. Young was a law clerk for Associate Justice Lamar US District Court – Northern District of Illinois W. Baker of the California Second District Court of Appeal, Division Five, where he drafted opinions on various issues. In addition, he cite-checked and record- EDUCATION checked drafts and separate opinions for circulation to other chambers, UCLA School of Law, J.D. (specialization in International and Comparative Law) proofread opinions prior to filing, and observed oral arguments to assist Justice Baker in making decisions. Prior to this, he was a post-bar fellow at the Los University of Minnesota Law School (first-year Angeles County Public Defender’s Office, where he drafted motions, conducted coursework), Dean’s List, Dean Distinguished Scholarship, Richardson Scholarship legal research, interviewed clients, and assisted with trial efforts.

UCLA, B.A., Economics and Sociology While attending law school at UCLA, Mr. Young was an Associate Editor of the LANGUAGES UCLA Law Review and participated in the 2016 American Red Cross Clara Cantonese (conversational) Barton International Humanitarian Law Competition, where his team was French (basic) German (basic) awarded “Best Overall Team Research and Writing.” In addition, he worked as a certified legal intern for the San Diego County Public Defender’s Office and focused on complex securities fraud cases, represented clients at arraignment, and participated heavily in a trial, including examination of witnesses.

Mr. Young is a member of the American Bar Association, the Bar Association of San Francisco, and the Los Angeles County Bar Association. He also volunteers his time for the local San Francisco community. He has given talks with local organizations to youth interested in a future legal career and has volunteered as an essay reviewer for students currently applying to colleges.

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OUR TEAM – STAFF ATTORNEYS JOSEPH SAVER! LAW FIRM

Elissa A. Buchanan

Ms. Buchanan’s legal expertise focuses on antitrust, construction defect, and corporate securities and shareholder litigation. She plays an active role in deposition and trial preparation and manages a team of document reviewers tasked with analyzing and organizing extensive e-discovery. She works primarily on antitrust drug cases involving pay-for-delay, PBM (pharmacy benefit management or manager) kickbacks, and generic drug company collusion. She takes pride in providing positive outcomes for consumers and overall fairness in the healthcare system.

Ms. Buchanan also has taken the lead role in forming the Firm’s “Green Team,” a group of employees who have organized personnel and implemented policy changes to ensure that the Firm is environmentally responsible. They have successfully achieved the Firm’s designation as a Certified Green Business by the San Francisco Green Business Program. PRACTICE AREAS Antitrust Intellectual Property Prior to joining the Firm, Ms. Buchanan worked as a contract attorney on

ADMISSIONS construction defect litigation and antitrust and personal injury class actions. State of California During law school, she interned at California Lawyers for the Arts, where she worked with clients to find solutions to copyright and trademark issues. She EDUCATION also was a technical editor for the Journal of Law and Social Justice and University of San Francisco School of Law, J.D. volunteered for Law in Motion, a program that provides opportunities for the law Mills College, B.A., French Studies school community to reflect on issues of social justice and access to equal justice through various activities and events. LANGUAGES French (conversational reading and speaking) Ms. Buchanan is a member of the American Bar Association.

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OUR TEAM – STAFF ATTORNEYS JOSEPH SAVER! LAW FIRM

Julie Han

Ms. Han focuses on antitrust and consumer class actions, while representing plaintiffs through each phase of antitrust litigation from pre-trial investigation, discovery, dispositive motions, witness selection and interviews, to trial preparation. She understands the goals that need to be reached beyond the complex disputes over antitrust matters. Focused on serving her clients in the best way possible, she aggressively approaches every issue developed during litigation and effectively tackles it to grant her clients a successful resolution.

Prior to joining the Firm, Ms. Han was a project managing attorney for a major international law firm in the San Francisco Bay Area, where she supervised discovery review teams and assisted the firm’s intellectual property litigation.

PRACTICE AREAS During law school, as a legal intern at the Office of Legislation and Policy of the Antitrust California Department of Corporations, Ms. Han reviewed legislation proposals Class Actions on California finance and mortgage lending law and drafted analysis of the

ADMISSIONS state lending issues. State of California

EDUCATION Ms. Han is a member of the American Bar Association and the Bar Association University of the Pacific, McGeorge School of of San Francisco. Law, J.D.

San Francisco State University, B.S., Business Administration (concentration in International Business)

Chung-Ang University (Seoul), B.A., Architectural Engineering

LANGUAGES Japanese (professional level) Korean (native level)

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OUR TEAM - DOCUMENT REVIEW ATTORNEYS JOSEPH SAVER! LAW FIRM

Sean Bockover

Mr. Bockover specializes in antitrust, class action, and intellectual property. He uses his excellent English and German communication abilities and attention to detail to efficiently process evidence in complex litigation. Then, using analytical skill earned in the sciences, plus tenacity and a thirst for justice honed in public defender work, he turns those insights into action.

For his junior year of college, Mr. Bockover studied at the University of Constance in southwestern Germany, where he became fluent in German. After receiving a B.A. from Cornell University, he returned to Germany for a non-degree year at the University of Heidelberg. After attending the Indiana University Mauerer School of Law (where he was active in the Indiana Law Journal) he spent two years as an associate at a boutique Indiana-based firm, practicing mostly criminal law in indigent defense cases. Mr. Bockover then left PRACTICE AREAS Indiana for a career in e-discovery (in English and German) in the Bay Area. Antitrust For more than a dozen years, he has been reviewing documents for top-tier Class Action Intellectual Property firms, preparing depositions, reviewing contracts, and other tasks in German for intellectual property and commercial law cases and investigations covering ADMISSIONS pharmaceuticals, semiconductor, co-location, software, and automotive State of California disputes. EDUCATION Indiana University Maurer School of Law, J.D., cum laude Mr. Bockover is a member of the American Bar Association.

Cornell-Heidelberg Exchange, Universität Heidelberg, Germany

Cornell University, B.A., Biology and German Literature, Dean’s List

LANGUAGES German (fluent) Japanese (basic)

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OUR TEAM - DOCUMENT REVIEW ATTORNEYS JOSEPH SAVER! LAW FIRM

Heather Du

Ms. Du specializes in antitrust and class action litigation. She has more than 10 years of e-discovery experience that focuses on complex discovery and document review projects using a variety of e-discovery technologies. She also assists in other aspects litigation, including legal research, interview/deposition preparation, and other analytical assignments to support the Firm in providing the best representation to the clients.

Before joining the Firm, Ms. Du was a contract attorney/document reviewer at several San Francisco top tier law firms, where she reviewed documents in securities, patent litigation, class action, civil investigation, and other related practice areas.

Previously, Ms. Du served as a volunteer attorney for the Volunteer Homeless Advocacy Project (“HAP”), where she provided limited scope representation at PRACTICE AREAS Antitrust court-mandated settlement conferences and assisted with trial preparation. She Class Action assisted individuals and families at the Volunteer Legal Service Program of the ADMISSIONS Bar Association of San Francisco. She was a law clerk for the Asian Pacific State of California US District Court – Northern District of California Islander Legal Outreach and performed a clinical internship for the San Francisco-based Eviction Defense Collaborative. She also interned at the San EDUCATION University of San Francisco School of Law, J.D. Francisco based Court House Project and HAP.

University of San Francisco, B.A., Politics, cum laude Ms. Du is a member of the American Bar Association and the Bar Association LANGUAGES of San Francisco. Vietnamese (reading and writing) Cantonese (basic)

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OUR TEAM - DOCUMENT REVIEW ATTORNEYS JOSEPH SAVER! LAW FIRM

Nanci Murdock

Ms. Murdock specializes in class action, antitrust, and business litigation. She brings her extensive litigation experience to her current position with the Firm where she performs an integral role in analyzing probative documents of clients and participants to identify merits of claims, potential witnesses, and key evidence in complex class actions.

Prior to joining the Firm, Ms. Murdock was a litigator at two major law firms and of counsel at a Los Angeles boutique litigation firm. She has a successful appellate and business litigation background and has crafted winning motions and appeals throughout her career. Her respondents’ brief for United States Supreme Court case Musick, Peeler & Garrett v. Employers Insurance of Wausau, 508 U.S. 286 (1993), was affirmed in favor of her clients. Another appeal was also affirmed with the California Court of Appeal, which adopted, in entirety, the arguments proffered in her respondent’s brief. She won an appeal PRACTICE AREAS in a case that had been ongoing for nine years and had been before the Antitrust Class Action California Supreme Court three times. And she had a new trial motion and a Complex Business Disputes judgment notwithstanding the verdict motion granted, overturning a $3.7 million ADMISSIONS verdict in a case of first impression interpreting a California statute. State of California State of New York State of Massachusetts US Supreme Court Ms. Murdock also has a substantial intellectual property background. As an IP US Court of Appeals – Ninth Circuit associate, she worked on various copyright matters and won a partial summary US District Court – Central District of California judgment in the Ninth Circuit in a “work for hire” case involving a major rock EDUCATION star. She had a temporary restraining order granted in a trademark dispute Loyola University Law School, J.D., Dean’s List involving a well-known leisure-wear manufacturer, and successfully opposed a University of Southern California, B.A., English/Humanities preliminary injunction in a trade secrets/submission of ideas case before the Second Circuit.

While attending law school, Ms. Murdock was named to the Moot Court Team and won both the Moot Court Best Brief Award and the West Publishing Company Award for Outstanding Brief Writing. She thereafter honed her writing skills clerking for Presiding Justice Joan Dempsey Klein of the California Court of Appeal. Although she originally had a one-year clerkship, after seven months she was asked to stay on as senior attorney and became one of the most junior attorneys ever selected for that position.

Prior to attending law school, Ms. Murdock worked in the Mayor’s Office of Los Angeles and the City Community Development Department. In those positions she researched and analyzed city ordinances and federal HUD proposals; authored reports for proposed city legislation; and made legislation recommendations to the city council.

Ms. Murdock is a member of the American Bar Association.

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OUR TEAM - DOCUMENT REVIEW ATTORNEYS JOSEPH SAVER! LAW FIRM

Esther Oh

Ms. Oh specializes in class actions and other complex civil litigation, with a focus on antitrust. She enjoys working on complex litigation through the process of uncovering facts underneath the evidence presented, and then advocating those facts on behalf of disadvantaged purchasers and consumers.

Ms. Oh uses her knowledge of both information technology and legal processes to analyze clients’ electronically stored data to identify merits of claims, potential witnesses, and relevant facts and issues relative to litigation. She also conducts legal research and performs other duties to ensure that clients receive the best and most cost-effective legal solutions.

Prior to joining the Firm, Ms. Oh clerked for the Honorable Gerald Lebovits of the New York State Supreme Court and was a trial attorney at a boutique New

PRACTICE AREAS York City law firm. Throughout law school, she was a judicial intern to the Antitrust Honorable Richard Ringell, Karen Howze, Andrea Harnett, and Marisa Demeo Class Action of the Superior Court of the District of Columbia. She was also a student attorney at the Took Crowell Institute for At-Risk Youth Clinic in Washington, ADMISSIONS State of New York D.C.

EDUCATION University of the District of Columbia, David A. Ms. Oh is a member of the American Bar Association and the Bar Association Clark School of Law, J.D., Dean’s Fellow of San Francisco.

New York University, B.S., Social Work

LANGUAGES Korean (native level)

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OUR TEAM - DOCUMENT REVIEW ATTORNEYS JOSEPH SAVER! LAW FIRM

Randy S. Salenfriend

Mr. Salenfriend specializes in antitrust, class action, business litigation, and research. His passion for assisting those in need of outstanding legal representation is what drove him to pursue a law career. As a result, he is guided by the principles of ethics, confidentiality, compassion, and loyalty in the practice of law.

In his current role with the Firm, Mr. Salenfriend has played an integral role in analyzing critically important documents, including the communications of participants and others in complex class action cases against dozens of generic drug manufacturers who are accused of fixing the prices of numerous generic drugs.

Mr. Salenfriend has practiced law for several years in the San Francisco Bay PRACTICE AREAS Area before countless Federal and State Courts, in both the Northern District Antitrust Class Action and Southern District. He specializes in antitrust, class action, and complex Complex Business Disputes business disputes.

ADMISSIONS State of California Before joining the Firm, Mr. Salenfriend served as counsel for Attorneys in US Court of Appeals – Ninth Circuit Motion, working on various legal matters ranging from law and motion hearings, US District Court – Central District of California US District Court – Eastern District of California workers’ compensation, and status and settlement conferences to taking and US District Court – Northern District of California defending depositions. He accumulated extensive document review experience US District Court – Southern District of California as a contract attorney for Fronteo, a publicly traded global technology and EDUCATION services company, and assorted legal staffing agencies. Thomas Jefferson School of Law, J.D./B.S.L.

LANGUAGES For many years, Mr. Salenfriend was General Counsel and Vice-President & Spanish (conversing, reading and writing) Manager of Legal Affairs for CrossCheck, Inc. (Petaluma, California), a check approval and financial services corporation, and its subsidiary, Optio Solutions. Prior to that, he worked in civil practice for various Bay Area firms and made regular appearances before numerous California courts.

While in law school, Mr. Salenfriend was a Graduate Legal Intern in the Correctional Law Section of the California Attorney General’s Office, where he conducted extensive research and drafted memoranda and appellate briefs on behalf of the People of California. In his first year of law school, he also earned the prestigious American Jurisprudence Award for Contracts.

Mr. Salenfriend is a member of the Bar Association of San Francisco. While a resident of San Francisco, he was appointed President of the San Francisco Drug Abuse Advisory Board by unanimous vote of the Board of Supervisors.

Prior to working in law, Mr. Salenfriend was a sportswriter for the Atlanta Journal-Constitution and other publications.

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OUR TEAM – OF COUNSEL

Joshua P. Davis, Of Counsel

Professor Davis has been involved in class actions in general and in antitrust class actions for over twenty years. He was a partner at Lieff Cabraser Heimann & Bernstein LLP until he joined the law faculty of the University of San Francisco School of Law, where he is currently the Director of its Center for Law and Ethics after serving 2013-2017 as Associate Dean for Academic Affairs.

Professor Davis is one of the foremost scholars in the country on private antitrust enforcement and class certification in antitrust cases. He has done award-winning original empirical and theoretical analysis of private antitrust cases, and his scholarship has been cited by federal appellate and trial courts. He has published dozens of law review articles on such topics as private antitrust enforcement, class certification, legal ethics, jury instructions, and PRACTICE AREAS injunctive relief, as well as on free speech doctrine, jurisprudence, and artificial Antitrust intelligence and the law. Class Action Consumer Protection Legal Ethics Professor Davis has been retained by plaintiffs’ counsel to brief and argue

ADMISSIONS before federal appellate courts in antitrust cases. He has also briefed and State of California argued motions to dismiss, for class certification, to exclude expert testimony, US District Court – Northern District of California and for summary judgment in Magnetic Iron Oxide Antitrust Litigation, Truck Numerous other federal and state jurisdictions Card Antitrust Litigation, In re Lidoderm Antitrust Litigation, In re Capacitors EDUCATION Antitrust Litigation, In re Restasis Antitrust Litigation, and Le v. Zuffa, among Georgetown University, LLM other cases. New York University School of Law, J.D., Order of the Coif Brown University, B.A. Professor Davis regularly presents at academic conferences on civil procedure, LANGUAGES class certification, legal ethics, class action ethics, antitrust litigation, and French (conversational) Spanish (conversational) artificial intelligence and the law. He has made presentations, among other Hebrew (basic) places, at the Northern District of California Judicial Conference, the U.S. Japanese (basic) Department of Justice Antitrust Division, the California Department of Justice, the American Bar Association, the American Antitrust Institute, the Bar Association of San Francisco, the Federal Bar Association, the Practicing Law Institute, the Pound Institute, the International Legal Ethics Conference, and various law schools.

Professor Davis regularly provides legal commentary in print, radio and television media. He helped organize the 2019 and 2020 releases of the Antitrust Report: Class Action Filings in Federal Court, issued by The Huntington National Bank and the University of San Francisco School of Law, which surveyed the antitrust field of recent years. In 2019, he also spoke at the University of Haifa’s (Israel) 3rd International Conference: Dispute Resolution of Consumer Mass Disputes, Collective Redress, Class Action, and ADR. He has testified before Congress on civil procedure and was the reporter for the task force and committee that drafted the California Supreme Court rules governing multijurisdictional practice. He also serves on the Board of the American Antitrust Institute.

Professor Davis serviced as a law clerk to Patrick Higginbotham of the U.S. Court of Appeals for the Fifth Circuit. During law school at New York University, he received the Frank H. Sommer Award for top general scholarship and achievement in class and was Senior Articles Editor of the New York University Law Review.

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Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Joseph Saveri Law Firm, LLP Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Williams, Steven P 37.00 $1,100.00 $40,700.00 Williams, Steven P 342.80 $1,050.00 $359,940.00 Williams, Steven P 22.50 $1,000.00 $22,500.00 Saveri, Joseph P 2.20 $1,050.00 $2,310.00 Saveri, Joseph P 1.50 $1,000.00 $1,500.00 Giblin, Gwendolyn A 500.50 $650.00 $325,325.00 Giblin, Gwendolyn A 165.30 $635.00 $104,965.50 Malone, Katharine A 29.70 $625.00 $18,562.50 Dallal, James A 18.70 $575.00 $10,752.50 Dallal, James A 97.80 $550.00 $53,790.00 Gibboney, Kyla A 192.80 $550.00 $106,040.00 Gibboney, Kyla A 9.90 $475.00 $4,702.50 Quackenbush, Kyle A 29.40 $450.00 $13,230.00 Quackenbush, Kyle A 543.10 $425.00 $230,817.50 Quackenbush, Kyle A 590.60 $400.00 $236,240.00 Oh, Esther A 478.70 $385.00 $184,299.50 Oh, Esther A 899.50 $375.00 $337,312.50 Du, Heather A 344.10 $385.00 $132,478.50 Du, Heather A 959.50 $375.00 $359,812.50 Salenfriend, Randy A 30.50 $385.00 $11,742.50 Salenfriend, Randy A 61.00 $375.00 $22,875.00 Manuel, Ryan A 0.80 $375.00 $300.00 Buchanan, Elissa A 24.80 $375.00 $9,300.00 Day, Jenel PL 25.90 $395.00 $10,230.50 Day, Jenel PL 3.10 $375.00 $1,162.50 Aulkh, Gurjit PL 3.00 $375.00 $1,125.00 Lockett, Dwayne PL 6.90 $385.00 $2,656.50 Lockett, Dwayne PL 0.20 $375.00 $75.00 Ponce, Ruby PL 1.10 $385.00 $423.50 Ponce, Ruby PL 6.00 $375.00 $2,250.00 Robertson, Sean PL 282.30 $375.00 $105,862.50 VanDeMortel, Daniel PL 2.00 $375.00 $750.00 Malhan, Ryan PL 0.50 $300.00 $150.00 Malhan, Ryan PL 1.00 $250.00 $250.00 Haile, Heaven PL 17.00 $375.00 $6,375.00 Haile, Heaven PL 80.20 $275.00 $22,055.00 Haile, Heaven PL 277.60 $250.00 $69,400.00 TOTALS 6089.50 $2,812,261.50

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 144 of 228 PageID# 11339

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Joseph Saveri Law Firm LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $126,422.00 Filing / Misc. Fees Overnight Delivery/Messengers $3,041.66 Photocopying $2,338.00 Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $21,227.04 Litigation Fund Contributions $612,000.00 Expert Fees $6,150.00 Secretarial OT / Word Processing Court Reporter Service/Transcript Fees $4,228.19 Microfilm / Video / Disks Duplication TOTAL $775,406.89 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 145 of 228 PageID# 11340

Exhibit A-4 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 146 of 228 PageID# 11341

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: l 8-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF CONRAD M. SHUMADINE IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE A WARDS TO THE CLASS REPRESENTATIVES

I, Conrad M. Shumadine hereby declare as follows:

1. I was a shareholder (partner) at the law firm of Willcox & Savage, P.C. until June

30, 2020, when I nominally retired. I stayed on with Willcox & Savage in a limited capacity to

complete this case. The court appointed my firm Liaison Counsel for Indirect Purchaser Plaintiffs

("IPPs"). I submit this declaration in support ofIndirect Purchaser Plaintiffs' Motion for an Award

ofAttorneys' Fees, Reimbursement ofExpenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. I was admitted to practice law in the Commonwealth of Virginia in 1967 and have

been continually licensed and in good standing since that time and hold bar license number 4325.

4. My firm has acted as counsel for IPPs in this litigation on an entirely contingent

basis. Willcox & Savage, P.C. is described in the firm overview which is attached hereto, together

with my background and experience as set forth in my resume, both of which are attached hereto

collectively as Exhibit A.

5. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation. This includes work performed by my firm's attorneys and Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 147 of 228 PageID# 11342

professional staff: computed at my firm's historical hourly rates, through February 28, 2021.

6. The total number of hours expended in this litigation by my firm through February

28, 2021 is 630.16. The total lodestar for my firm is $300,094. Based on my knowledge of rates in

this market, my firm's rates are appropriate. The total attorney aud professional staff time reflected

in this declaration is based on my firm's contemporaneous, daily time records regularly prepared

and maintained by my firm.

7. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

8. As detailed in Exhibit C, my firm has incurred a total of$ 2,718.74 in unreimbursed

costs and expenses in this litigation through March 31, 2021. My firm advanced these costs and

expenses with no assurance that such costs and expenses would be repaid. My firm has only set

forth costs and expenses incurred through March 31, 2021, in accordance with the guidelines

established by Interim Co-Lead Counsel.

9. The costs and expenses incurred in this action are reflected on the books and records

ofmy firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

10. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 29th day of April, 2021 in Norfolk, Virginia. &11""'2 Jff. fa½,,.,~;_ Conrad M. Shumadine Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 148 of 228 PageID# 11343

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 149 of 228 PageID# 11344 Willcox Savage

Firm Overview

Willcox Savage is a full-service business law fi rm located in Southeastern Virginia. While our roots have been deeply planted in this community since About the Firm 1895, we enjoy relationships with local, regional, national and international clients. With 60 Firm established in 1895. attorneys, the fi rm is large enough to off er a wide range of expertise while still off ering our clients the benefi t of a personal relationship. Over sixty attorneys dedicated to serving clients from our Norfolk, Virginia, offi ce. We represent many international, national and regional companies in the area, along with major municipalities. These clients demand successful Designated an AV-rated fi rm through coordination of their legal services and maximum Martindale-Hubbell’s peer review process. effi ciency, and we are pleased to serve as their legal counsel. Nearly three-quarters of our partners are PRACTICE AREAS recognized as Best Lawyers in America, • Antitrust Virginia Super Lawyers and/or as Virginia’s • Arbitration Legal Elite. • Asbestos Defense • Creditors’ Rights Recognized by Chambers USA as a leading • Business Immigration law fi rm. • Catastrophic Insurance Defense • Commercial Real Estate • Construction Contracts Our attorneys serve on over 100 civic and • Construction Litigation professional boards throughout Virginia. • Corporate, Securities & Finance • Employee Benefi ts • Environmental MANAGING PARTNER • Government Contracting Robert L. Dewey • Health Care • Intellectual Property MAIN OFFICE • International Trade Wells Fargo Center • Labor & Employment 440 Monticello Avenue, Suite 2200 • Maritime Norfolk, Virginia 23510 • Partnerships, Joint Ventures & LLCs (757) 628-5500 • Premises & Products Liability • Taxation • Tort Defense • Transportation • Trusts & Estates Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 150 of 228 PageID# 11345 WILLCOX SAVAGE

Conrad M. Shumadine Member Phone 757.628.5525 Fax 757.628.5566 [email protected]

Conrad M. Shumadine received a J.D. degree from Harvard Law School in 1967 and received an A.B. degree from Davidson College in 1964. Conrad was admitted to the bar of the Supreme Court of Virginia in Practice Area 1967, has been continually licensed and in good standing since that Commercial Litigation time, and has maintained a litigation practice since his admission. He Education holds Bar License Number 4325. Conrad had an active litigation practice J.D. Harvard University, for more than 54 years. 1967 A.B. Davidson College, Conrad has lectured extensively on litigation and other legal matters in 1964 Virginia and elsewhere in the United States. For more than 25 years, he was a permanent member of the faculty of the Practising Law Institute Memberships Communications Law Seminar, a yearly held seminar for Virginia State Bar communications lawyers. Conrad has written a number of articles and American Bar Association outlines including a more than 500-page outline concerning Antitrust Virginia Bar Association Law and the Media utilized in connection with the Communications Law Norfolk Portsmouth Bar Seminar. Association, Former President Conrad is a member of the bars of the Supreme Court of the United Virginia Trial Lawyers States, the United States Court of Appeals for the Fourth Circuit, the Association United States Court of Appeals for the Ninth Circuit, the United States Judicial Conference, Fourth Court of Appeals for the Second Circuit, the United States Court of Circuit Court of Appeals Appeals for the Federal Circuit, the United States District Court for the Western District of Virginia, and the United States Bankruptcy Courts for Professional Recognition this District and the Western District of Virginia. He is a permanent American College of Trial member of the Judicial Conference of the United States Court of Lawyers: Fellow Appeals for the Fourth Circuit. Conrad has been admitted Pro Hac Vice Virginia Law Foundation: to other federal district courts throughout the country. Fellow Conrad was a member of the American Bar Association, the Virginia Bar American Bar Foundation: Fellow Association, the Federal Bar Association, the Norfolk and Portsmouth Bar Association, and the Virginia Trial Lawyers Association. He served as Best Lawyers in America, president of the Norfolk and Portsmouth Bar Association and was a Antitrust Law, Appellate member and chairman of the Virginia State Bar Section of Antitrust Law. Law, Banking Law, Conrad was a member and chairman of the Virginia State Bar Second Business Litigation, District Disciplinary Committee. Conrad is a Fellow of the American Financial Institutions and College of Trial Lawyers, a Fellow of the American Bar Foundation, and a Transaction Law, Fellow of the Virginia Law Foundation. Commercial Litigation, First Amendment Law, Bet-the- Company Litigation

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 151 of 228 PageID# 11346 WILLCOX SAVAGE

Professional Recognition Conrad was chairman of the Merit Selection Panels which were (cont’d) Norfolk Best Lawyers appointed to make recommendations for the appointment of a Appellate Practice Lawyer Magistrate Judge for the United States District Court for the Eastern of the Year (2012, 2020) District of Virginia for the years 2000 and 2012. In 2017, Conrad was chairman of the Advisory Panel appointed by this Court in connection AV Peer Review Rating by with the reappointment of the Honorable Douglas E. Miller as a LexisNexis Martindale- Magistrate Judge of this Court. Hubbell Recognized as a leading Conrad has been awarded an “AV” rating in the Martindale Hubbell Commercial Litigator in peer ranking process. the 2005-2017 Editions of Conrad has been listed in Best Lawyers in America in the fields of Chambers USA: America's Antitrust Law, Appellate Law, Banking Law, Business Litigation, Financial Leading Lawyers for Institutions and Transaction Law, Commercial Litigation, First Amendment Business Law and Bet-the-Company Litigation. Best Lawyers in America, Lawyer of the Year - In 2016, the Norfolk and Portsmouth Bar Association awarded Conrad Appellate Practice, 2014, the Eggleston/I’Anson Professionalism Award which honors a Norfolk 2020; Litigation/Antitrust, Portsmouth Bar Association member who has exemplified the highest 2013, 2020 standards of professionalism throughout his or her career. Virginia's "Legal Elite," In 2018, Conrad was named to the “Virginia Lawyers Hall of Fame” by Virginia Business Virginia Lawyers Weekly. The honor recognizes attorneys age 60 and magazine older who have a history of dedication to law in Virginia. Virginia Super Lawyers "Top 50" in state Conrad was named to Virginia’s “Legal Elite” published by Virginia Business magazine in the field of civil litigation since its inception in Virginia Super Lawyers – 2000. He was also named a “Virginia Super Lawyer” in the field of Business Litigation business litigation and has been listed as among the top 50 lawyers in Benchmark Litigation: the Commonwealth by Richmond Magazine, as well as being identified Leading Litigator, Virginia as a “top lawyer” in the field of business litigation by Corporate Counsel magazine. Conrad was recognized as a leading litigation attorney by Chambers USA and as a “Benchmark Litigation Star” for Virginia.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 152 of 228 PageID# 11347 WILLCOX SAVAGE

Examples of Experience

• Began his antitrust practice by representing major film distributors in a case challenging “splits.”

• Represented a major shoe chain in defending price fixing and monopolization claims.

• Represented the local newspaper in First Amendment matters for over fifty years as well as assisting tv stations and, on occasions, networks in First Amendment matters.

• Assisted a small publisher in Arkansas in preventing two of its competitors from being acquired by a national media conglomerate or its agent.

• Successfully defended McClatchy Newspapers, Inc. from a challenge made to its $300 million acquisition of the News & Observer Publishing Company in Raleigh, North Carolina.

• Successfully represented the News & Observer Publishing Company (publisher of the Raleigh News & Observer) in obtaining summary judgment in a lawsuit filed in the United States District Court for the Southern District of New York by AD/SAT, Inc. alleging that the News & Observer participated with the Associated Press and others in a conspiracy to monopolize the market for satellite advertising distribution.

• Represented a joint venture composed of major New York Stock Exchange and private companies registered under the National Cooperative Research and Production Act of 1993 on how the joint venture should operate to avoid antitrust difficulties.

• Continued to assist in the representation of a major chemical company in defending the company in connection with a price fixing investigation undertaken by the United States Department of Justice.

• Assisted another New York Stock Exchange company in completing a major acquisition involving pre-merger notification pursuant to the Hart-Scott-Rodino Act.

• Continued to provide ongoing antitrust counseling, including antitrust compliance seminars, to a whole series of clients.

• Obtained Justice Department clearance for The Arkansas Democrat to acquire its direct competitor, The Arkansas Gazette.

• Represented The Anchorage Times in the sale of substantially all of its assets to The Anchorage Daily News.

• Obtained a directed verdict in favor of a nationwide toy manufacturer accused of discriminatory pricing and monopolization.

• Obtained a directed verdict on discriminatory pricing and promotion claims brought against a foreign automobile manufacturer.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 153 of 228 PageID# 11348 WILLCOX SAVAGE

• Defended the president of a national soft drink company against criminal price fixing charges and a class action lawsuit.

• Represented the only defendant to obtain summary judgment on price fixing and horizontal market division claims brought against four dairy companies by the Virginia Attorney General.

• Obtained summary judgment on behalf of a nationwide newspaper chain in an antitrust action brought in the Northern District of Mississippi. The case involved claims of discriminatory pricing and predatory pricing.

• Obtained summary judgment on exclusive dealing, monopolization and market division claims brought against a nationwide newspaper chain in Greensboro, North Carolina.

• Obtained a substantial settlement and a consent decree governing future competition for a western Virginia newspaper in danger of being run out of business by its competitor's predatory pricing.

• Successfully defended a major health care provider from claims seeking to void its contracts with physicians.

• Was lead counsel in preventing an attempt by a competitor to prevent the opening of the area’s then largest shopping mall.

• Was lead counsel for a local developer in litigation that invalidated the City of Virginia Beach’s attempt to downzone the rural section of the City and make the developer’s property virtually worthless.

• Assisted numerous financial institutions in major litigation including one lawsuit that literally saved the institution.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 154 of 228 PageID# 11349

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Willcox & Savage, P.C. Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Shumadine, Conrad P 509.16 $550.00 $280,038.00 Yoder, Patty PL 37.60 $155.00 $5,828.00 Yoder, Patty PL 56.00 $160.00 $8,960.00 Yoder, Patty PL 18.00 $165.00 $2,970.00 Bryant, Gary P 0.40 $445.00 $178.00 Fogerty, Bethany A 8.50 $225.00 $1,912.50 Spain, Brett P 0.50 $415.00 $207.50

TOTALS 630.16 $300,094.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 155 of 228 PageID# 11350

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Willcox & Savage, P.C. Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees Overnight Delivery/Messengers $38.92 Photocopying $2,408.75 Postage Service of Process Fees Telephone / Fax $34.80 Transportation / Meals / Lodging $236.27 Litigation Fund Contributions Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $2,718.74 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 156 of 228 PageID# 11351

Exhibit A-5 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 157 of 228 PageID# 11352

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF SHPETIM ADEMI IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION :FOR AN A WARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Shpetirn Aderni, hereby declare as follows:

1. I am a partner at the law firm Ademi LLP, f/k/a Ademi & O'Reilly LLP. I submit

this declaration in support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys'

Fees, Reimbursement of Expenses, and Service A wards to the Cla'is Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Ademi LLP and its attorneys are

summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 917.8. The total lodestar for my firm is $351,028. My firm's lodestar amount includes Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 158 of 228 PageID# 11353

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm's attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm's contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm's lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. AH of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $61,581.20 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $60,000 in

contributions to the Indirect Purchaser Plaintiffs' joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 159 of 228 PageID# 11354

Executed this 28th day of April 2021 in Cudahy Wisconsin

Shpetim Ademi Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 160 of 228 PageID# 11355

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 161 of 228 PageID# 11356

Attorneys at Law

Milwaukee | Madison

FIRM BIOGRAPHY

We litigate securities, antitrust, and consumer class actions. The firm also practices federal bankruptcy law and federal appellate law.

The Firm’s Attorneys

Guri Ademi graduated from the University of Wisconsin—Milwaukee magna cum laude in 1990 and the University of Wisconsin Law School in 1993, serving as a Notes and Comments Editor for the Wisconsin Law Review. After interning with Judge Thomas Curran of the Eastern District of Wisconsin, he was an associate with Quarles & Brady LLP in its corporate finance and antitrust groups from 1993 to 2000 and an associate with Whyte Hirschboeck Dudek S.C. in its securities and antitrust groups from 2000 to 2001. He joined Ademi LLP in 2001 and heads its securities litigation practice group. Guri is recognized as a Wisconsin Super Lawyer in Wisconsin Super Lawyers.

Shpetim Ademi, the firm’s founder, graduated cum laude from the University of Wisconsin—Milwaukee in 1992, with honors in philosophy and history and an honors thesis in philosophy. He graduated from the University of Wisconsin Law School in 1996. After interning with Judge Charles B. Schudson of the Wisconsin Court of Appeals, 1st District, he founded the Southside Law Office in 1996 and serves as managing partner of Ademi LLP and heads its Antitrust and Consumer litigation groups. Shpetim is recognized as a Wisconsin Super Lawyer in Wisconsin Super Lawyers every year since 2009. Shpetim was also included on Super Lawyers’ Top 50 Wisconsin list 2016, 2018, 2019 and 2020 and Top 25 Milwaukee list for 2016, 2019 and 2020.

John D. Blythin graduated cum laude from the University of Wisconsin-Madison in 1999, with a degree in political science and from University of Wisconsin Law School in 2003. He is of counsel, practicing in securities, antitrust, and consumer litigation. John is also admitted to practice in the State of Illinois.

Mark A. Eldridge graduated from Marquette University in 2006, with a double major in Journalism and Psychology and from Marquette University Law School in 2014. He is an associate, practicing in securities, antitrust, and consumer litigation. Mark is listed as a Rising Star in Wisconsin Super Lawyers 2020.

Denise L. Morris graduated magna cum laude from Columbia University in 2005, with a degree in Philosophy and magna cum laude from DePaul University College of Law in 2014. She is an associate, practicing in securities, antitrust, and consumer litigation. Denise is also admitted to practice in the State of New York.

Jesse Fruchter graduated cum laude from State University of New York College of Environmental Science and Forestry in 2005, with a B.S. in Environmental Biology. Jesse also obtained his M.S. in Plant Biology from Southern Illinois University in 2012. Finally, Jesse graduated cum laude from the University of Wisconsin Law School in 2017. He is an associate, practicing in securities, antitrust, and consumer litigation. Jesse is listed as a Rising Star in Wisconsin Super Lawyers 2020.

Ben J. Slatky graduated with distinction from the University of Wisconsin in 2007 with a B.A. in Philosophy and English Literature. Ben also obtained his M.A. in English Literature from University of York in 2011. Finally, Ben graduated from the University of Wisconsin Law School in 2017. He is an associate, practicing in securities, antitrust, and consumer litigation. Ben is listed as a Rising Star in Wisconsin Super Lawyers 2020. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 162 of 228 PageID# 11357

Firm Biography Page 2 of 4

FIRM HIGHLIGHTS

SECURITIES CLASS ACTIONS

IN RE: SPIEGEL, INC. SECURITIES LITIGATION (N. D. IL 2002) We represented the class as Co-Lead counsel in this action. Settlement of $17.5 million.

IN RE: EFUNDS CORPORATION SECURITIES LITIGATION (D. AZ 2002) We represented the class as Co-Lead counsel in this action. Settlement of $2.5 million.

IN RE: SYNTROLEUM CORP. SHAREHOLDER LITIGATION (TULSA COUNTY OK 2013) We represented the class as Co-Class counsel in this action. Additional consideration of $2.8 Million.

IN RE: METAVANTE TECHNOLOGIES, INC. SECURITIES LITIGATION (MILWAUKEE COUNTY, WI 2009) We represented the class as Co-Lead counsel in this action. Settlement of additional disclosures to shareholders.

IN RE: JOURNAL MEDIA GROUP, INC. SHAREHOLDER LITIGATION (MILWAUKEE COUNTY, WI 2015) We represented the class as Co-Lead counsel in this action. Settlement of additional disclosures to shareholders.

IN RE: QUOVADX INC. SECURITIES LITIGATION (D. CO 2003) We represented the lead plaintiff and class as counsel in this action. Settlement of $9 million.

IN RE: DHB INC. SECURITIES LITIGATION (E.D.N.Y. 2005) We represented one of the lead plaintiffs and the class as counsel in this action. Settlement estimate of $64 million.

IN RE: NORTHWESTERN CORP. SECURITIES LITIGATION (D.S.D. 2003) We represented secondary offering shareholders and certain bondholders. Settlement of $40 million.

IN RE: RAYOVAC, INC.. SECURITIES LITIGATION (W.D. WI 2003) We represented the class as Liaison counsel in this action. Settlement of $4 million.

IN RE: MERGE TECHNOLOGIES (MILWAUKEE COUNTY, WI 2006) We represented the class as Liaison counsel in this derivative action. Settlement of corporate governance reforms.

KANDEL V. GEHL COMPANY, ET AL. (WASHINGTON COUNTY, WI 2008) We represented the class as Liaison counsel in this action. Settlement of additional disclosures to shareholders.

IN RE: TOMOTHERAPY, INC. SECURITIES LITIGATION (W.D. WI 2008) We represented the class as Liaison counsel in this action. Settlement of $5 million.

IN RE: PUSKALA V. KOSS CORPORATION (E.D. WI 2010) We represented the class as Liaison counsel in this action. Settlement of $1 million.

IN RE ENERGYSOLUTIONS, INC. SHAREHOLDER LITIGATION (DEL. CH. 2013) We represented the class as Co-Counsel in this action. Increased merger consideration by approximately $36 million.

AMO V. INTEGRYS ENERGY GROUP, INC. (MILWAUKEE COUNTY, WI 2014) We represented the class as Liaison counsel in this action. Settlement of additional disclosures to shareholders.

IN RE WAUSAU PAPER CORP. SHAREHOLDER LITIGATION (MILWAUKEE COUNTY, WI 2015) We represented the class as Liaison counsel in this action. Settlement of additional disclosures to shareholders.

REPRESENTATIVE RECENTLY FILED SECURITIES CLASS ACTIONS:

AURORA CANNABIS INC. (D.N.J) GRUBHUB INC. (N.D. ILL.) AGRIA CORP. (S.D.N.Y.) IMPAX LABORATORIES, INC. (S.D. CA) CARBONITE, INC (D. MASS.) IMPERIAL CHEMICALS (S.D.N.Y.) CORN PRODUCTS INTERNATIONAL, INC. (N.D. IL) MEREDITH CORPORATION (S.D. IA) CORUS BANKSHARES, INC. (N.D. IL) NU SKIN ENTERPRISES, INC. (D. UT) DIRECT GENERAL CORPORATION (M.D. TN) OCA, INC. (E.D. LA) ESCALA, INC. (S.D.N.Y.) PARAMETRIC CORPORATION (D. MA) FIFTHTHIRD CORPORATION (N.D. OH) PETCO ANIMAL SUPPLIES, INC. (S.D. CA) FIRST ENERGY CORP (S.D. OH) TRIPATH TECHNOLOGIES (C.D. CA)

REPRESENTATIVE RECENTLY FILED DERIVATIVE, CORPORATE GOVERNANCE AND BUYOUT CLASS ACTIONS:

AMERICAN REALTY CAPITAL HEALTHCARE TRUST, INC. (MD) INTERMAGNETICS GENERAL CORP. (NY) ANWORTH MORTGAGE ASSET CORP. (CA) JOY GLOBAL INC. (WI) BEAR STATE FINANCIAL HOLDINGS LLC (AR) KEANE , INC. (MA) CRAFT BREW ALLIANCE INC. (OR) NORTHSTAR ASSET MANAGEMENT GROUP (MD) CONNECTICUT WATER SERVICE, INC. (CT) PERSPECTA INC. (NV) COMMUNITYONE BANCORP. (W.D. NC) RIGGS NATIONAL CORP. (DE) CRAFT BREW ALLIANCE, INC. (OR) RITA MEDICAL SYSTEMS, INC. (CA) EDUCATION REALTY TRUST, INC. (MD) STEC, INC. (CA) EMC INSURANCE GROUP INC. (IA) STERLING BANCORP.(NY) GOLDEN WEST FINANCIAL CORP. (CA) VECTREN CORPORATION (S.D. IND) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 163 of 228 PageID# 11358

Firm Biography Page 3 of 4

ANTITRUST CLASS ACTIONS

EDWARDS ET AL V. NATIONAL MILK PRODUCERS FEDERATION ET AL. (N.D. CAL 2011) We currently represent the class of indirect purchasers as co-class counsel. Settlements of $52 million pending.

IN RE: POLYURETHANE FOAM ANTITRUST LITIGATION MDL DKT. NO. 2196 (N.D. OH 2010) We represented the class of indirect purchasers as co-class counsel. Settlements of over $151 million.

AL'S DISCOUNT PLUMBING LLC, ET AL. V. VIEGA LLC, (M.D. PA 2019) We represented the class of indirect purchasers as co-class counsel. Settlement valued at $15 million.

IN RE: INTERIOR MOLDED DOORS INDIRECT PURCHASER ANTITRUST LITIGATION, (E.D. VA 2018) We represent the class of indirect purchasers as co-class counsel. Settlement of $19.5 million pending.

IN RE: AUTOMOTIVE WIRE HARNESS SYSTEMS ANTITRUST LITIGATION MDL NO. 2311 (E. D. MI 2011) We represent the indirect purchaser class as co-counsel in this action. Settlements of over $1.2 billion.

IN RE: PACKAGED SEAFOOD PRODUCTS ANTITRUST LITIGATION - MDL DKT. 2670 (S.D. CAL 2015) We represent the indirect purchaser class of end users as co-counsel in this action. Settlements of $20 million pending.

IN RE: CATHODE RAY TUBE ANTITRUST LITIGATION - MDL DKT. NO. 1917 (N.D. CAL 2008) We currently represent the class of indirect purchasers as co-class counsel. Settlements of over $609 million pending.

IN RE: AUTOMOTIVE REFINISHING PAINT ANTITRUST LITIGATION - MDL DKT. NO. 1426 (E.D. PA 2001) We acted as co-counsel for the class of direct purchasers in more than 20 lawsuits brought against the major car paint manufacturers, including Sherwin Williams, Akzo Nobel, DuPont, PPG Industries and BASF. Settlement of more than $108 million.

IN RE: FRESH AND PROCESS POTATOES ANTITRUST LITIGATION. - MDL DKT. NO. 2186 (E.D. PA 2010) We represented the class of indirect purchasers as co-class counsel. Settlement of over $5 million.

IN RE: INTERNATIONAL AIR TRANSPORTATION SURCHARGE ANTITRUST LIT. - MDL DKT. NO. 1793 (N.D. CAL 2006) We represented the class as co-counsel in this action. Settlement of over $200 million.

BLESSING ET AL V. SIRIUS XM RADIO INC. (S.D. NY 2009) We represented the class as co-counsel in this action. Settlement valued at over $180 million.

FOND DU LAC BUMPER EXCHANGE INC V. JUI LI ENTERPRISE COMPANY LTD ET AL (E.D. WI 2010) We represented the third-party payor indirect purchaser class as a Liaison Counsel in this action. Settlements of $8 million.

IN RE: TEXT MESSAGING ANTITRUST LITIGATION - MDL DKT. NO. 1997 (N.D. IL 2008) We represented the proposed class on plaintiff’s steering committee in this action.

IN RE: POTASH ANTITRUST LITIGATION - MDL DKT. NO. 1996 (N.D. IL 2008) We represented the indirect purchaser class as co-counsel in this action. Settlement of $21.5 million.

REPRESENTATIVE RECENTLY FILED ANTITRUST CLASS ACTIONS:

IN RE: HARD DISK DRIVE SUSPENSION ASSEMBLIES ANTITRUST LITIGATION - MDL DKT. 2918, (N.D. CAL 2019)

IN RE: QUALCOMM ANTITRUST LITIGATION - MDL DKT. 2773 (N.D. CAL 2017)

IN RE: DOMESTIC AIRLINE TRAVEL ANTITRUST LITIGATION - MDL DKT. NO. 2656 (D.C. 2015)

IN RE: DISPOSABLE CONTACT LENS ANTITRUST LITIGATION - MDL DKT. NO. 2626 (M.D. FL 2015)

IN RE: KEURIG GREEN MOUNTAIN SINGLE-SERVE COFFEE ANTITRUST LITIGATION - MDL Dkt. No. 2542 (S.D. NY 2014)

IN RE VEHICLE CARRIER SERVICES ANTITRUST LITIG., MDL NO. 2471 (N.J. 2013)

IN RE: ELECTRONIC BOOKS ANTITRUST LITIGATION - MDL DKT. NO. 2293 (S.D. NY 2011)

IN RE: PHOTOCHROMIC LENS ANTITRUST LITIGATION - MDL DKT. NO. 2173 (M.D. FL 2010)

IN RE: MUSICAL INSTRUMENTS AND EQUIPMENT ANTITRUST LITIGATION - MDL DKT. NO. 2121 (S.D. CAL 2009)

IN RE: PROCESSED EGG PRODUCTS ANTITRUST LITIGATION - MDL DKT. NO. 2002 (E.D. PA 2008)

IN RE: AFTER MARKET AUTO FILTERS ANTITRUST LITIGATION - MDL DKT. NO. 1957 (N.D. IL 2008)

IN RE: PACKAGED ICE ANTITRUST LITIGATION - MDL DKT. NO. 1952 (E.D. MI 2008)

IN RE: CHOCOLATE CONFECTIONARY - MDL DKT. NO. 1917 (N.D. PA 2008)

LAFLAMME ET AL. V. SOCIETE AIR FRANCE ET AL.. (E.D. NY 2008)

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 164 of 228 PageID# 11359

Firm Biography Page 4 of 4

CONSUMER CLASS ACTIONS

MCKINNIE V. CHASE BANK (E.D. WI 2008) We represented the class as Lead Counsel in this action under the Electronic Funds Transfer Act. Settlement of $2.1 million.

ORI V. FIFTH THIRD BANK AND FISERVE, INC. (E.D. WI 2008) We represented the class on the Lead Class Counsel Committee in this action under the Fair Credit Reporting Act. Settlement valued at over $3 million.

IN RE: LIBERTY REFUND ANTICIPATION LOAN LITIGATION MDL DKT. NO. 2334 (N.D. IL 2012) We represented the class on the Lead Counsel Executive Committee in this action. Settlement of $5.3 million.

LIPTAI V. SPECTRUM BRANDS HOLDINGS, INC. ET AL (DANE COUNTY. WI 2018) We represented the class as Co-Lead Counsel in this action. Settlement of $2.25 with additional equitable relief.

IN RE: WELLS FARGO AUTO INSURANCE MARKETING AND SALES PRACTICES LITIGATION MDL DKT. 2797 (C. D. CAL 2017) We represented the class as co-counsel in this action. Settlement estimate pending of over $432 million.

IN RE: DOLLAR GENERAL CORP. MOTOR OIL MARKETING AND SALES PRACTICES LITIGATION MDL NO. 2709 (W. D. MO 2016) We represent the certified class of Wisconsin consumers as co-lead counsel and several other class states as co-counsel in this action. Preliminary approval granted.

IN RE: PILOT FLYING J FUEL REBATE CONTRACT LITIGATION MDL NO. 2358 (2013) We represented the class as Settlement Class Counsel in this action. Settlement valued at $72 million of full refund plus interest to the class.

IN RE: BOA CREDIT PROTECTION MARKETING AND SALES PRACTICES LITIGATION MDL DKT. NO. 2269 (N.D. CAL 2011) We represented the proposed class as co-counsel. Settlement of $20 million.

IN RE: CHASE BANK USA, N.A., “CHECK LOAN” CONTRACT LITIGATION – MDL DKT. NO. 2032 (N.D. CAL 2009) We represented the proposed class as co-counsel. Settlement of $100 million.

KARDONICK ET AL., V. J.P. MORGAN & CO. CHASE (S.D. FL 2010) We represented the class as co-counsel. Settlement of $21.5 Million.

IN RE: SAMSUNG TOP-LOAD WASHING MACHINE MARKETING, SALES PRACTICES AND PRODUCTS LIABILITY- MDL DKT. 2792 (W. D. OK 2017) We represented the class as co-counsel in this action. Settlement estimate pending of over $125 million available to class members.

IN RE: COUNTRYWIDE FINANCIAL CORP. CUSTOMER DATA SECURITY BREACH MDL DKT. NO. 1998 (W.D. KY 2008) We represented the class as co-counsel in this action. Settlement value estimated at over $200 million.

IN RE: HEARTLAND PAYMENT SYSTEMS, INC., CUSTOMER DATA SECURITY BREACH MDL DKT. NO. 2046 (S.D. TX 2009) We represented the class as a member of the Steering Committee in this action. Settlement valued at over $4.5 million.

NEWMAN ET AL V. COMPLYRIGHT, INC., (N.D. IL 2018) We represented the class as co-counsel in this action. Settlement of over $3 million.

IN RE: HYUNDAI HORSEPOWER LITIGATION CA. SUP. CT. (2003) We represented a United States and Canadian class of purchasers of Hyundai motor vehicles as co-counsel. Settlement of more than $100 million.

IN RE SONY PS3 “OTHER OS” LITIGATION, (N.D. CAL 2010) We represented the class as co-counsel in this action. Settlement of 3.75 million.

PERDUE ET AL V. HY-VEE, INC. (C.D. IL 2019) We represented the class as co-counsel in this action. Preliminary approval granted

IN RE WAWA, INC. DATA BREACH LITIGATION (E.D. PA 2019) We represented the class as co-counsel in this action. Settlement value up to 44 million subject to court approval.

IN RE OCEAN BANK FINANCIAL CORP. PRE-SCREENING LITIGATION - MDL DKT. NO. 1998 (N.D. IL 2006) We represented a Wisconsin class as Lead Counsel in this action under the Fair Credit Reporting Act.

BERNAL V. AMERICAN MONEY CENTERS, INC. (E.D. WI 2005) We represented a Wisconsin class as Lead Counsel in this action under the Fair Credit Reporting Act.

REPRESENTATIVE RECENTLY FILED CONSUMER CLASS ACTIONS:

IN RE: ERIE COVID-19 BUSINESS INTERRUPTION PROTECTION INS. LITIG. MDL NO. (W.D. P N. 2021)

NEWMAN V. TOTAL QUALITY LOGISTICS LLC,. (S.D. OH 2020)

IN RE: CAPITAL ONE CONSUMER DATA SECURITY BREACH LITIGATION MDL NO. 2915 (E.D. VA 2019)

IN RE: AMERICAN MEDICAL COLLECTION AGENCY, INC., CUSTOMER DATA SECURITY BREACH LITIGATION MDL NO. 2904 (D. N.J. 2019)

BLOCK V. WISCONSIN HOSPITALITY GROUP LLC (E.D. WI 2019)

T&M FARMS V. CNH INDUSTRIAL AMERICA LLC (E.D. WI 2019)

IN RE: INTEL CORP. CPU MARKETING, SALES PRACTICES AND PRODUCTS LIABILITY LITIGATION MDL NO. 2828 (2018)

IN RE: EQUIFAX, INC., CUSTOMER DATA SECURITY BREACH LITIGATION MDL DKT. 2800 (N.D. GA 2017)

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 165 of 228 PageID# 11360

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Ademi LLP Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar SHPETIM ADEMI P 63.20 $ 750.00 $47,400.00 JOHN D. BLYTHIN OC 0.20 $ 475.00 $95.00 MARK A. ELDRIDGE A 86.50 $ 410.00 $35,465.00

DENISE MORRIS (review rate) A 422.80 $ 300.00 $126,840.00 DENISE MORRIS A 337.80 $ 410.00 $138,498.00 JESSE FRUCHTER A 7.00 $ 375.00 $2,625.00 BEN SLATKY A 0.30 $ 350.00 $105.00

TOTALS 917.8 $351,028.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 166 of 228 PageID# 11361

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Ademi LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees Overnight Delivery/Messengers Photocopying $125.80 Postage Service of Process Fees Telephone / Fax $21.02 Transportation / Meals / Lodging $1,434.38 Litigation Fund Contributions $60,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $61,581.20 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 167 of 228 PageID# 11362

Exhibit A-6 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 168 of 228 PageID# 11363

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF VAN BUNCH IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Van Bunch, hereby declare as follows:

1. I am a partner at the law firm of Bonnett, Fairbourn, Friedman & Balint, P.C. I

submit this declaration in support of Indirect Purchaser Plaintiffs’ Motion for an Award of

Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Bonnett, Fairbourn, Friedman &

Balint, P.C. and its attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 16.4. The total lodestar for my firm is $11,080.00. My firm’s lodestar amount includes Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 169 of 228 PageID# 11364

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $5,028.40 in unreimbursed

costs and expenses in this litigation through March 31, 2021, including $5,000 in contributions to

the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these costs and expenses

with no assurance that such costs and expenses would be repaid. My firm has only set forth costs

and expenses incurred through March 31, 2021, in accordance with the guidelines established by

Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 170 of 228 PageID# 11365

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed Executed this 21st day of April, 2021 in Phoenix, Arizona.

______

Van Bunch Bonnett, Fairbourn, Friedman & Balint, P.C. 2325 E. Camelback Road, Suite 300 Phoenix, Arizona 85016 Tel: 602-274-1100 Fax: 602-274-1199 [email protected]

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 171 of 228 PageID# 11366

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 172 of 228 PageID# 11367

r:1 r■:1 BONNETT FAIRBDURN 1:1111 FRIEDMAN & BALINT PC

11m

ABOUT THE FIRM

Bonnett, Fairbourn, Friedman & Balint, P.C. is an AV rated firm of 19 lawyers. Our clients include many individuals and local businesses, as well as major national and international companies in a wide range of civil litigation in both federal and state courts.

The firm has developed a recognized practice in the area of complex commercial litigation, including major class actions and is widely regarded as the preeminent firm in Arizona representing plaintiffs in class action proceedings. Over the last twenty years, the firm has successfully handled more than 100 class action lawsuits. We have represented consumers and victims in a wide range of class action proceedings, including actions alleging antitrust claims, securities fraud, civil rights claims and consumer fraud.

Our antitrust practice includes the prosecution of class claims on behalf of direct purchasers of products as well as indirect purchaser claims. These antitrust cases include, among others, class actions against Microsoft, MasterCard, Apple Computer and sellers of products such as polyester and rubber chemicals, waste management services, financial products and other industries. In addition to our class action practice, the firm also has represented plaintiffs in individual litigation asserting antitrust claims, including Culligan International.

Bonnett, Fairbourn, Friedman & Balint has taken a leading role in numerous important actions on behalf of consumers and investors, and we have been responsible for many outstanding results that have yielded dozens of multi-million dollar recoveries for class members in Arizona and throughout the United States.

Bonnett, Fairbourn, Friedman & Balint, P.C. 2325 E. Camelback Road, Suite 300 Phoenix, Arizona 85016 Phone: (602) 274-1100 Toll Free Number: (800) 847-9094 Facsimile: (602) 274-1199

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 173 of 228 PageID# 11368

PRACTICE AREAS

CLASS ACTION

Bonnett, Fairbourn, Friedman & Balint represents consumers and investors in major class action cases in federal and state courts throughout the United States. Under the direction of Andrew S. Friedman, the firm's class action section represents plaintiff classes in the following areas:

Securities Fraud: Protects institutional shareholders and individual investors from corporate fraud and mismanagement.

Consumer Protection: Protects consumers from defective products and fraudulent marketing practices.

Antitrust: Protects individuals and businesses from price fixing, unfair business practices and other anticompetitive conduct.

Civil Rights and Employment: Protects employees and consumers against unfair practices and racial, age, gender, and other forms of discrimination.

Insurance and Health Care: Represents victims of fraud and unfair sales practices by life insurance companies and HMOs.

Tobacco: Seeks redress for fraudulent marketing of "Light" cigarettes as a less toxic version of "Full Flavor" varieties.

False Claims and Whistleblowers: Provides for awards to individuals who uncover false claims for payment submitted to the federal government.

SECURITIES

Bonnett, Fairbourn, Friedman & Balint has extensive experience in plaintiffs' class action securities cases in and out of the State of Arizona. Its attorneys have recovered substantial verdicts and settlements in various high-profile cases representing bondholders who have suffered significant losses due to the criminal activities of individuals in the securities and banking industries, including victimized investors in the Lincoln Savings scandal.

APPELLATE LITIGATION

Bonnett, Fairbourn, Friedman & Balint has extensive appellate experience at all levels of the state and federal court systems. Attorneys from the firm have appeared before the Arizona Court of Appeals, the Arizona Supreme Court, and numerous U.S. Circuit Courts. Decisions to appeal a matter are not made lightly by the firm; we carefully analyze the likelihood of a positive result for the client against the potential cost of an unfavorable outcome. Although we draw on the clerking and practical experience of many of our attorneys in making this analysis, a fully informed client is always an integral part of this process. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 174 of 228 PageID# 11369

VAN BUNCH is a firm shareholder. Mr. Bunch’s practice focuses on class action and mass tort litigation. He has represented clients in class litigation involving breach of contract, federal and state securities laws, federal and state RICO actions, deceptive insurance sales practices, environmental pollution and other consumer protection claims.

Recently, Mr. Bunch participated in the successful resolution of Good, et al. v. West Virginia American Water Company in the United States District Court for the Southern District of West Virginia. The case arose of a spill of hazardous chemicals into the local water supply of Charleston, W.V., shutting down access to drinking water for some 225,000 residents and thousands of businesses. Mr. Bunch served as lead counsel in the case and worked all phases of the litigation up to the eve of trial, when the parties struck a settlement. Before that, Mr. Bunch steered In re Mingo County Coal Slurry litigation to a successful conclusion, a case in which over seven hundred West Virginians received compensation for physical injuries, including wrongful death claims and the establishment of a medical monitoring program to help promote earlier diagnosis and treatment from the health effects of alleged exposure to coal slurry in their water supplies.

Mr. Bunch served as trial counsel in Smith v. American Family, a case involving the use of imitation crash parts in repair estimates for consumers in the state of Missouri, which resulted in a unanimous jury verdict of approximately $30 million in March, 2007. The case paid tens of thousands of Missourians full compensation, with interest, for their losses.

Mr. Bunch also served as trial counsel in Lebrilla v. Farmers Insurance Group in Santa Ana Superior Court, which settled following a complete bench trial in 2006 resulting in readjustment of auto property damage claims for Farmers' insureds nationwide following settlement.

Mr. Bunch served as trial counsel for the investor class in In re American Continental Corporation/Lincoln Savings and Loan Securities Litigation, MDL 834. The recovery achieved for investors, after several years of highly adversarial litigation and a months-long trial, exceeded $250 million.

Mr. Bunch served as Co-Lead counsel in the MDL proceedings of In re Polaris Aircraft Income Fund, which resulted in a settlement valued at approximately $110 million.

Mr. Bunch also litigated a series of cases involving the sale of so-called "vanishing premium" life insurance policies, including cases against Prudential Insurance and MetLife, which alone returned over $3 billion to defrauded policyholders. Other cases included actions against New York Life, John Hancock, Equitable of Iowa, American General and others. He litigated Manners v. American General Life Assurance Company in the United States District Court for the Middle District of Tennessee, which involved the sale of so-called "industrial" life insurance policies and alleged race discrimination in premium setting. He served as local counsel for the Class in the indirect purchaser anti-trust action against Brand Name Prescription Drug makers in Davidson County (Tennessee) Circuit Court, which returned over $7 million in prescription drug benefits distributed through community health centers throughout Tennessee.

Mr. Bunch served as co-editor of the Class Actions and Derivative Suits Subcommittee of the ABA Section of Litigation newsletter. He actively participates in pro bono work, including Tennessee’s “On-Line TN Justice” resource. He also served on the Signal Mountain, Tennessee Planning Commission and is a Board Member of the Tennessee River Gorge Trust. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 175 of 228 PageID# 11370

Mr. Bunch received his Bachelor of Arts Degree from Vanderbilt University in 1979. He received his law degree in 1984 from the George C. Taylor School of Law at the University of Tennessee, where he earned membership in the Order of the Coif. Mr. Bunch was admitted to the Bar in Arizona in 1984, Tennessee in 1996 and West Virginia in 2007; he is admitted to practice before the U.S. District Court for the District of Arizona, U.S. District Court for the Middle District of Tennessee and U.S. District Court for the Southern District of West Virginia.

Mr. Bunch was associated with Evans, Kitchel & Jenkes, P.C., a large Phoenix law firm from 1984- 1986. In 1986, Mr. Bunch joined Bonnett, Fairbourn, Friedman & Balint, P.C., where he became a shareholder in 1989.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 176 of 228 PageID# 11371

BONNETT, FAIRBOURN, FRIEDMAN & BALINT, P.C.

ATTORNEYS

WILLIAM G. FAIRBOURN, born Salt Lake City, Utah, April 21, 1947; admitted to bar, 1973, Arizona; Arizona Supreme Court; U.S. District Court, District of Arizona; United States Court of Appeals, Ninth Circuit. Education: University of Utah (B.S., 1970); Arizona State University (J.D., 1973). Member: Maricopa County Bar Association (Member, Board of Directors, 1984-1986); Arizona Association of Defense Counsel (Member, Board of Directors, 1981-1989; President, 1986); American Board of Trial Advocates (President Phoenix Chapter, 1994); Fellow, American College of Trial Lawyers.

ANDREW S. FRIEDMAN, born Plainfield, New Jersey, September 26, 1953; admitted to bar, 1978, Arizona; U.S. Court of Appeals, Ninth Circuit; U.S. District Court, District of Arizona; U.S. Supreme Court. Education: University of Rochester (B.A., with high distinction, 1975); Duke University (J.D., with high distinction, 1978). Order of the Coif. Member: State Bar Committee on Civil Practice and Procedure (1980-1984); State Bar Committee on Bench-Bar Relations (1991); State Bar Bankruptcy Section; National Association of Commercial Trial Attorneys (1991-present); American Bar Association, Trial Practice Committee, Subcommittees and Class and Derivative Actions.

FRANCIS J. BALINT, JR., born Pittsburgh, Pennsylvania, January 9, 1957; admitted to bar, 1982, Virginia and District of Columbia; 1983, Arizona; U.S. District Court, Districts of Arizona and Virginia; U.S. Court of Appeals, Fourth and Ninth Circuits; U.S. Supreme Court. Education: University of Virginia (B.A., with high distinction, 1979; J.D., 1982). Former President: Arizona Association of Defense Counsel (Member, Board of Directors 1988 - 2001).

VAN BUNCH, born Chattanooga, Tennessee, April 28, 1957; admitted to bar, 1984, Arizona; 2007, West Virginia; U.S. District Court, District of Arizona. Education: Vanderbilt University (B.A., 1979); University of Tennessee at Knoxville (J.D., with high honors, 1984). Order of the Coif.

ROBERT J. SPURLOCK, born Janesville, Wisconsin, November 23, 1954; admitted to Arizona bar, 1984; U.S. District Court, District of Arizona. Education: University of Wisconsin-Madison (B.S., with honors, 1976), Arizona State University (J.D., 1984). Law Clerk to the Honorable D.L. Greer, Arizona Court of Appeals, 1984-1985; Member: Phoenix Association of Defense Counsel; Defense Research Institute; Arizona Association of Defense Counsel; American Bankruptcy Institute. Adjunct Professor, Sandra Day O’Connor School of Law, Arizona State University.

C. KEVIN DYKSTRA, born Phoenix, Arizona, March 30, 1964; admitted to Arizona bar, 1989; U.S. Court of Appeals, Ninth Circuit; U.S. District Court, District of Arizona. Education: Northern Arizona University (B.S., 1986); California Western School of Law (J.D., 1989). Director, Arizona Association of Defense Counsel. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 177 of 228 PageID# 11372

ELAINE A. RYAN, born Emmetsburg, Iowa, June 15, 1963; admitted to Arizona bar, 1989; Texas bar, 2008; Kansas bar, 2010; Missouri bar, 2010; Washington bar, 2010; Colorado bar, 2011; Utah bar, 2011; Idaho bar, 2011; U.S. District Court, District of Arizona; U.S. District Court, District of Eastern Michigan; U.S. District Court, District of Idaho; U.S. District Court, Western District of Wisconsin; U.S. District Court, Northern District of Illinois. Education: University of Iowa (B.S., with distinction, 1986); Duke University (J.D., 1989).

ANDREW Q. EVERROAD, born Phoenix, Arizona, August 8, 1969; admitted to Arizona bar, 1995; U.S. District Court, District of Arizona. Education: University of Arizona (B.A., 1992); University of London – Bloomsburg, 1990; Arizona State University (J.D., 1995). Law Clerk to the Honorable Thomas C. Kleinschmidt, Arizona Court of Appeals, 1995-1996.

PATRICIA N. SYVERSON, born San Diego, California, July 16, 1975; admitted to California bar, 1999; Arizona bar, 2000; U.S. District Court, Central and Southern Districts of California; U.S. District Court, District of Arizona. Education: University of California at San Diego (B.A., 1996); California Western School of Law (J.D., 1999).

KIMBERLY C. PAGE, born Washington, D.C., February 16, 1968; admitted to Georgia bar, 1993; Alabama bar, 1993; Arizona bar, 2004; U.S. District Court, Northern, Middle and Southern Districts of Alabama; U.S. Court of Appeals, Eleventh Circuit. Education: Miami University (B.A., 1990); Cumberland School of Law of Samford University (J.D., magna cum laude, 1993).

CHRISTINA L. PUSATERI, born Ames, Iowa, September 16, 1968; admitted to Arizona bar, 1995; U.S. Court of Appeals, Ninth Circuit, 1997; U.S. District Court, District of Arizona. Education: Arizona State University (B.A., summa cum laude, 1989); Arizona State University College of Law (J.D., cum laude, 1995). Associate Articles Editor, Arizona State University Law Journal, 1994-1995. Law Clerk to Hon. E. G. Noyes, Jr., Arizona Court of Appeals, 1995-1996.

WILLIAM F. KING, born Phoenix, Arizona, October 21, 1978; admitted to Arizona bar, 2005; U.S. District Court, District of Arizona. Education: Rockhurst College (B.A., 2001); Creighton University School of Law (J.D., cum laude, 2005). Lead Articles Editor, Creighton Law Review, 2004-05.

T. BRENT JORDAN, born Urbana, Illinois, November 21, 1967; admitted to Minnesota bar, 1993, Pennsylvania bar, 2003; U.S. District Court, Eastern District of Pennsylvania. Education: University of Illinois (B.A., B.S., magna cum laude, 1990); University of Minnesota Law School (J.D., cum laude, 1993). Judicial Clerk, U.S. Magistrate Judge Raymond L. Erickson, U.S. District Court, District of Minnesota, 1993-1995.

TY D. FRANKEL, born Phoenix, Arizona, November 13, 1983; admitted to Arizona bar, 2009; U.S. District Court, District of Arizona; U.S. Court of Appeals, Ninth Circuit. Education: Boston College (B.A., Dean’s List, 2006); Boston College Law School (J.D., cum laude, 2009).

CARRIE A. LALIBERTE, born Juneau, Alaska, December 9, 1989; admitted to Arizona bar, 2015; U.S. District Court, District of Arizona. Education: Washington State University (B.S., magna cum laude, 2012); Arizona State University College of Law (J.D., cum laude, 2015). Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 178 of 228 PageID# 11373

LISA T. HAUSER, born Kansas City, Missouri, March 13, 1956; admitted to bar, 1981, Arizona; Arizona Supreme Court; U.S. District Court, District of Arizona; United States Court of Appeals, Ninth Circuit; U.S. Supreme Court. Education: University of Arizona (B.A., with high distinction, 1978); University of Arizona College of Law (J.D., 1981). Member: Arthritis Foundation of Arizona Leadership Board 2014-2016; University of Arizona Phoenix Alumnae Board of Directors 2004-2006; Foundation for Arizona’s Future 2001-2005; University of Arizona Alumni Association National Board of Directors 1995-1998; State Bar of Arizona Appointments Committee 1991-1995. Coach, Sandra Day O’Connor School of Law ABA National Appellate Advocacy Competition Team 2011.

NADA DJORDJEVIC, born Chicago, Illinois, June 25, 1970, admitted to Illinois bar, 2002; U.S. District Court for the Northern District of Illinois, 2002, Trial Bar, 2012; U.S. District Court for the Northern District of Indiana, 2004; United States Court of Federal Claims, 2004. Education: Grinnell College (B.A., Sociology, 1996); University of Illinois College of Law (J.D., summa cum laude, 2002), University of Illinois Law Review, Member 2000-2001, Symposium Editor, 2001-2002.

ANDREA M. WRIGHT, born Charlotte, North Carolina, February 5, 1990; admitted to Montana bar, 2016, Arizona bar, 2018; District Court, District of Arizona, 2018. Education: University of North Carolina at Chapel Hill (B.A. in English Literature and B.A. in Romance Languages, 2008); University of Virginia (J.D., 2016).

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 179 of 228 PageID# 11374

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust

Firm Name: Bonnett, Fairbourn, Friendman & Balint, P.C.

Reporting Period: Inception through February 28, 2021

Historical Total Hourly Total Name Status Hours Rate Lodestar Bunch, Van P 15.6 $700.00 $10,920.00 Creech, Rose PL 0.8 $200.00 $160.00

TOTALS 16.4 $11,080.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 180 of 228 PageID# 11375

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Bonnett, Fairbourn, Friendman & Balint, P.C. Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $3.00 Filing / Misc. Fees Overnight Delivery/Messengers Photocopying $25.40 Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging Litigation Fund Contributions $5,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $5,028.40 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 181 of 228 PageID# 11376

Exhibit A-7 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 182 of 228 PageID# 11377

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF RICHARD B. BRUALDI IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE A WARDS TO THE CLASS REPRESENTATIVES

I, Richard B. Brualdi, hereby declare as follows:

'1 I I. I am a partner at the law firm of The Brualdi Law Firm, P.C. I submit this

declaration in support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My fim1 has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of The Brualdi Lwa Firm, P .C. and

its attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel . This

includes work perfonned by my finn's attorneys and professional staff, computed at my finn's

historical hourly rates, for the period through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 458.2. The total lodestar for my firm is $137,460.00. My firm's lodestar amount Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 183 of 228 PageID# 11378

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm's attorneys and professional staff are the same as the usual and customary

hourly rates charged by my finn for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm's contemporaneous, daily time records regularly

prepared and maintained by my finn, as well as any reductions in my finn' s lodestar required by

Interim Co-Lead Counsel.

6. My finn complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

;:; I , declaration. All of the services performed by my film in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $30,000 in unreimbursed

costs and expenses in this litigation during the period from December 26, 2018 through March 31,

2021, including $30,000 in contributions to the Indirect Purchaser Plaintiffs' joint litigation fund.

My firm advanced these costs and expenses with no assurance that such costs and expenses would

be repaid. My finn has only set forth costs and expenses incurred between December 26, 2018,

and March 31, 2021, in accordance with the guidelines established by Interim Co-Lead Counsel.

[Continued on following page]

2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 184 of 228 PageID# 11379

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 29th day of April 2021 in New York, New York. RIJ!f:B.~Rt;-

3 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 185 of 228 PageID# 11380

EXHIBIT A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 186 of 228 PageID# 11381

THE RUALDI LAW FIRM,P.C.

FIRM BIOGRAPHY

The Brualdi Law Firm, P.C. (the “BLF”) was founded in 1998 by its principal, Richard B. Brualdi, in order to concentrate on lawsuits that serve the public good, with a particular emphasis on sophisticated class action litigation in the securities, antitrust and consumer areas, as well as corporate derivative lawsuits. It maintains its offices in downtown Manhattan, New York, one block from Wall Street and the New York Stock Exchange.

We believe that, over the years, we have developed a national reputation for excellence in the practice of law in the public service. This is reflected in the fact that we have achieved substantial results for plaintiffs in a wide variety of cases, and in the fact that Courts, both in our native northeast and throughout the country, have repeatedly certified us as class counsel or derivative counsel in sophisticated class actions as well as in corporate derivative lawsuits. Some highlights follow:

Class Actions

The BLF has successfully prosecuted a large number of class action lawsuits on behalf of shareholders and others. These include:

• In re Sprint Corporation Shareholders Litigation, Case No. Cv 0401714 (Johnson County, Kansas). The BLF was one of the plaintiffs’ lead counsel appointed by the Court to prosecute this shareholder class action asserting self-interest by the directors of Sprint Corporation in recombining a tracking stock dedicated to its wireless businesses back into the company as a whole. The case ultimately settled for $57.5 million paid to the Class.

• In Re AMICAS, Inc. Shareholder Litigation, Master File No. 10-412-BLS2 and 10-0174-BLS2 (Superior Court of Suffolk County, Massachusetts). The BLF was one of two plaintiffs’ lead counsel in a shareholder class action which, following the issuance of an injunction enjoining the merger from closing, resulted in an additional $31 million being paid to AMICAS’s shareholders.

• Jack G. Blaz v. Pan Pacific Retail Properties, et. al., Case No. 03-C-06-008085 (Circuit Court for Baltimore County, Maryland). The BLF was co-lead counsel in a shareholder class action which resulted in an additional $9.7 million being paid to shareholders.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 187 of 228 PageID# 11382

• Trading Strategies Fund v. Ezersky, et. al., Case No. 10 CV 333 (District Court of Douglas County, Kansas). The BLF was lead counsel in a shareholder class action in which, following the BLF’s obtaining of a temporary restraining order enjoining a Tender Offer from closing, an additional $3.25 million consideration was paid to shareholders in connection with the purchase of Protection One, Inc. by Golder Rauner II, L.L.C. and its affiliates.

• Hex Partners v. Mason N. Carter, Docket No.: L-246-10 (Superior Court of New Jersey, Law Division: Essex County). The BLF was principal plaintiff’s counsel in shareholder class action which resulted in post-closing litigation and a settlement amount of $2 million for shareholders of Merrimac Industries, Inc.

• Rational Strategies Fund v Hill, 2013 N.Y. Misc. LEXIS 3089 (N.Y. Sup. Ct. July 18, 2013) (Schweitzer, J.). The BLF was sole plaintiff’s counsel in shareholder class action in which the Court granted a preliminary injunction pending disclosure of information sought in complaint.

• In re Xicor, Inc. S’holder Litig., Master File No.: 1-04-CV-017801 (Superior Court of California, Santa Clara County). The BLF was co-lead counsel in a shareholder class action which, after post-closing litigation, resulted in an additional $2 million in consideration being paid to shareholders in connection with Intersil Corp.’s purchase of Xicor.

• Crafton, et. al. v. Powerwave Technologies, Inc., et. al., Case No 07-65 (Central District of California). The BLF was co-lead counsel for plaintiffs in a shareholder class action lawsuit alleging securities fraud claim against Powerwave Technologies, Inc. which resulted in $3,150,000 in cash being paid to Powerwave’s shareholders. In appointing The BLF as a co-lead counsel for plaintiffs, the United States District Court for the Central District of California noted that The BLF has shown that it has extensive experience litigating securities class actions.

• In re Intimate Brands, Inc. Shareholders Litig., No. 19380 (Delaware Court of Chancery). The BLF was one of an Executive Committee of plaintiffs’ counsel in a case that resulted in a settlement where the defendants agreed to pay shareholders tens of millions of dollars in additional money for their stock in Intimate Brands.

• Levy v. Hampden Bancorp, Inc., Case No. 15-00082 (Superior Court of Hampden County, Massachusetts). The BLF was principal counsel in a shareholder class action challenging the sale of Hampden Bancorp, Inc. to Berkshire Hills Bancorp, Inc. which, after post-closing litigation, resulted in a settlement of $1.8 million.

2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 188 of 228 PageID# 11383

• Short v. Churchill Benefit Corporation, et. al., Case No. 1:14-cv-04561-MKB-JO (United States District Court for the Eastern District of New York). In certifying the BLF as one of the counsel for the class in an action challenging improper wage deduction and failure to provide proper wage notice which resulted in a settlement of over $1 million, the Court found the BLF to be “experienced and well-qualified class-action attorneys.”

• In re Siliconix Inc. Shareholders Litig., C.A. No. 1143-NC (Delaware Court of Chancery). The BLF was one of plaintiffs’ lead counsel in this shareholder class action alleging that the majority shareholder of Siliconix was trying to acquire the remainder of the company for an unfairly low price. The case settled to the approval of the Court based on a $31.8 million increase in the price to be paid for remainder of company.

• In re Chiron Shareholder Deal Litigation, Case No. 05-2305667 (Superior Court of California, Alameda County). The BLF was one of principal plaintiffs’ counsel in shareholder class action which caused Novartis to increase an offer for that portion of Chiron Corporation it did not already own by over $300 million.

• In re 7-Eleven, Inc. Shareholders Litig., Cause No. 0508944-M (District Court of Texas). The BLF was one of the principal plaintiffs’ counsel in a shareholder class action which caused 7-Eleven Japan to increase price it was paying for that portion of 7-Eleven it did not already own by $145 million.

• In Re Harrah’s Entertainment Inc. Shareholder Litigation, Consolidated Case No. 2453-N (Delaware Court of Chancery). The BLF was one of principal plaintiffs’ counsel in shareholder class action which resulted in an additional over $1.6 billion dollars being paid to Harrah’s shareholders.

• In re Comair Holdings Inc., Shareholders Litig., No. 99 CI 1213 (Boone County, Kentucky). The BLF was one of plaintiffs’ lead counsel in a class action suit which challenged the actions of the directors of Comair Holdings in selling the company to its largest shareholder, Delta Air Lines, Inc., while discouraging other bidders through the imposition of a $50 million break-up fee. A settlement was reached whereby defendants agreed, inter alia, to rescind that break-up fee in its entirety – a settlement which drew substantial praise from the Court for The BLF’s efforts.

The BLF has also repeatedly received the praise of courts for its efforts as class counsel. Cases include:

• Cashstream Fund v. Paul L. Lamb, et al., Index No. 065134/2014 (Supreme Court of New York for Suffolk County). In certifying The BLF as counsel for the settlement class in a shareholder class action litigation and approving the settlement of the litigation in April, 2016, the Supreme Court of New York for

3 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 189 of 228 PageID# 11384

Suffolk County commended the BLF for its “hard work on behalf of . . . extensive and very able legal representation” of the Plaintiff class in the shareholder litigation and also commended the BLF’s work on behalf of shareholders as “benefit[ing] . . . society as whole.”

• Robert Garfield v. Capital Bank Financial Corp., et al., Case No. 16-1194 (Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida). In certifying the BLF as class counsel in an action on behalf of shareholders of Capital Bank Financial Corp. (“Capital Bank”) in connection with Capital Bank’s acquisition of CommunityOne Bancorp the Court noted “the fact that everybody [] put a lot of time and effort into [the Action] and resolved the matter [and that was] pretty darned good and a good indication of a couple of things. Number one is very competent counsel. Number two is the fact that [] all [counsel got] along decently, even though [they were in] an adversarial situation,” and further noted that the Court appreciated counsel’s efforts.

• Robert Garfield v. Heritage Oaks Bancorp, Case No. 17CV0097 (Superior Court of San Luis Obispo, California) (commending Mr. Brualdi for doing a “wonderful job” in representing shareholders of Heritage Oaks Bancorp in a preliminary injunction hearing in connection with its merger with Pacific Premier Bancorp).

• Margie Elstein v. Chambers Street Properties, et al., Docket No. MER-L-2254-15 (Superior Court of New Jersey, Mercer County) (certifying the BLF as class counsel for a class of Chambers Street Properties shareholders and finding that Mr. Brualdi was “eminently qualified to handle cases [protecting shareholders’ rights]”).

• Continuum Capital v. Nolan, et. al., No. 5687-VCL (Delaware Court of Chancery, February 3, 2011). In certifying The BLF as counsel for the settlement class in a shareholder class action litigation, the Delaware Court of Chancery, Vice Chancellor Laster Presiding, noted as follows:

Counsel is experienced in matters of this type and has been a plaintiff's counsel in many cases in this jurisdiction and elsewhere. In fact, this case was vigorously litigated, as I've discussed.

* * * * * Again, there is a lot to commend you for here, Mr. Brualdi. .. [Y]ou actually relitigated this thing. You took depositions. You really went after it. You got good disclosures. I mean, there’s a lot -- as I say, as a reviewing judge, there’s a lot to look at and say, “Mr. Brualdi and his team did a good job on this one.”

4 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 190 of 228 PageID# 11385

Derivative Actions

The results achieved over the years for shareholders in derivative actions by The BLF have also been substantial. They include the following:

• In re Bank of New York Corporate Derivative Litig., No. 99/604465 (Supreme Court of New York, New York County), a derivative suit brought by The BLF on behalf of The Bank of New York to recover for the substantial injury caused it through defendants allowing it to be infiltrated by alleged international criminals who then used it to launder billions of dollars in stolen money, including stolen International Monetary Fund monies, out of Russia and Eastern Europe. Following extensive litigation and discovery The BLF thereafter negotiated a settlement of this action pursuant to which the insurance carrier for defendants paid The Bank of New York $26.5 million dollars. The settlement also required the defendants to implement substantial corporate governance changes.

• In re Cendant Corporation Derivative Action Litigation, 98 Civ. 1998 (District of New Jersey). The BLF was one of plaintiffs’ counsel in a derivative action on behalf of Cendant Corporation which resulted in a $54 million recovery for the corporation.

• Harbor Finance Partners derivatively on behalf of M&F Worldwide Corp., No. 18592 (Delaware Court of Chancery). The BLF was one of plaintiffs’ counsel in case where a settlement providing for a recovery in excess of eighty-five million dollar was reached in the middle of trial.

• In re Sotheby’s Holdings, Inc., Derivative Litigation, 00 Civ. 1373 (Southern District of New York). The BLF was one of three counsel in action litigated in tandem with an action in the Michigan Courts and resulting in a multimillion dollar recovery for Sotheby’s Holdings, Inc.

• Sally Fernandes, derivatively on behalf of Plains All American, Inc., Civ. Action H-00-2359 (Southern District of Texas). The BLF was principal counsel in an action litigated in conjunction with an action in Delaware, and resulting in a multimillion dollar recovery for Plains All American.

• Elliot Walsey derivatively on behalf of Warner-Lambert Co., No. 99-5499 (District of New Jersey). The BLF was sole counsel in action litigated in conjunction with action in Delaware and resulting in Warner-Lambert Co. accepting an offer to be acquired by Pfizer, Inc., that was billions of dollars higher than an offer it originally accepted from American Home Products Co.

5 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 191 of 228 PageID# 11386

ATTORNEYS RICHARD B. BRUALDI Mr. Brualdi, the Firm’s founding partner grew up in southwestern Wisconsin before coming to New York City where he earned a Bachelor of Science degree with a major in Accounting from St. Johns University in 1985 and a Juris Doctor degree from Brooklyn Law School in 1988. At Brooklyn Law School, Mr. Brualdi served on the Brooklyn Law Review and the Moot Court Honor Society.

Following graduation from law school, Mr. Brualdi served for two years as law clerk to the Honorable Francis L. Van Dusen on the United States Court of Appeals for the Third Circuit. After leaving his clerkship with Judge Van Dusen, Mr. Brualdi was associated with the law firm Mudge Rose Guthrie Alexander & Ferdon, a firm which attained a measure of celebrity when both former President Richard M. Nixon and former Attorney General John Mitchell chose to practice there for many years. Thereafter, Mr. Brualdi was associated for a time with the Chicago based law firm Winston & Strawn, a firm which also achieved a measure of celebrity when former Vice-President Walter Mondale chose to practice there for a time. Thereafter, Mr. Brualdi founded The BLF.

Mr. Brualdi has received a number of awards for his contributions to the public service, including the Thurgood Marshall Award which was presented to Mr. Brualdi in 1998 by the Association of the Bar of the City of New York for his pro bono work on behalf of death row inmates in the State of Alabama. Mr. Brualdi has also done substantial committee work with various bar associations, including sitting for more than three years on the Association of the Bar of the City of New York’s Judiciary Committee, which among other things, was responsible, pursuant to arrangement with the Mayor of the City of New York, for giving final approval to the Mayor’s judicial nominees. Mr. Brualdi recently rejoined the Committee as an adjunct member.

Mr. Brualdi is admitted to the Bars of New York, New Jersey and the District of Columbia (inactive), as well as the United States Supreme Court, the United States Courts of Appeals for the Second, Third and Seventh Circuits, the United States District Courts for the Southern, Eastern, Northern and Western Districts of New York, and the United States District Court for the District of New Jersey.

JOHN F. KEATING, JR. Mr. Keating, the BLF’s Chief Trial Counsel, is a highly regarded litigator and trial lawyer with over 25 years’ experience representing plaintiffs and defendants. Mr. Keating has served as lead or co-lead plaintiffs’ counsel in numerous successful litigations, including cases against Merrill Lynch, Underwriters at Lloyds, Ericsson, and FFM, which collectively resulted in tens of millions of dollars in awards after trial and/or settlement. In 2004, Mr. Keating represented a leading telecommunications manufacturer as co-lead trial counsel in which his client obtained a very substantial recovery after a five week- long jury trial. Prior to his affiliation with the BLF, Mr. Keating successfully defended multinational and Fortune 500 companies against product liability and contract claims, and defended a high profile recording artist against a multi-million dollar civil assault and

6 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 192 of 228 PageID# 11387

battery lawsuit. Mr. Keating has also successfully argued before the Second Circuit Court of Appeals, and in the Ninth Circuit, in the case of Wilmington Trust Co v Connecticut Bank and Trust Co., the precedent–setting decision regarding the right to a jury trial under Rule 9(h) of the Federal Rules of Civil Procedure.

Mr. Keating earned his B.A. from Cornell University in 1976, an M.A. in Economics from the University of Maryland in 1981, a J.D. from Tulane University School of Law in 1982, and an LL.M in Taxation from New York University School of Law in 1991. He served as Law Clerk to the Honorable Patrick E. Carr of the United States District Court for the Eastern District of Louisiana from 1982 to 1984.

Mr. Keating is admitted to practice in New York, New Jersey, Florida, Connecticut, Louisiana and the District of Columbia.

GAITRI BOODHOO Ms. Boodhoo earned her B.A. cum laude in Political Science from Cedar Crest College and her J.D. from Brooklyn Law School. Prior to, and during law school, Ms. Boodhoo was a legal assistant in the litigation department of one of the top 10 law firms in the country. Prior to that, Ms. Boodhoo was an intern at the United Nations Development Program where she worked on a publication on poverty in Central Asia. While in law school, Ms. Boodhoo interned for the Honorable Herbert H. Altman of the Supreme Court of New York as well as in the legal department of Bank of America Merrill Lynch, then called Merrill Lynch.

Ms. Boodhoo focuses her practice on sophisticated securities class action litigation. She is also experienced in representing plaintiffs in labor and employment law matters as well as in complex tort litigation, including products liability, personal injury and wrongful death cases.

Ms. Boodhoo is admitted to the Bars of the State of New York and the United States District Courts for the Southern and Eastern Districts of New York.

7 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 193 of 228 PageID# 11388

DAVID MICHAEL TITUS

Mr. Titus has focused his practice on sophisticated securities class actions and derivative litigation for seven years. He previously worked as a Senior Staff Attorney in the LegalHealth unit of New York Legal Assistance Group, where he ran free legal clinics for patients at Lincoln Hospital, the James J. Peters VA Medical Center, and the Manhattan campus of the VA NY Harbor Healthcare System.

He earned his B.A. in English from Siena College and his J.D. from Brooklyn Law School. In law school, he earned the Joan Offner Touval Memorial Scholarship for best brief in the first-year legal writing program.

Mr. Titus is admitted to the Bars of the State of New York and the United States District Courts for the Southern and Eastern Districts of New York.

SOPHIA A. RAY

Ms. Ray earned her B.A. with honors in History from V. N. Karazin Kharkiv National University, Kharkiv, Ukraine. She earned her J.D. magna cum laude and Order of the Coif from Benjamin N. Cardozo Law School, to which she earned a Dean’s Merit Scholarship, and where she was a member of the Cardozo Law Review, a Dean’s Distinguished Scholar and a member of the Alexander Fellows Program. Ms. Ray is admitted to the New York Bar.

While in law school, Ms. Ray served as a Junior Law Clerk to the Honorable Laura T. Swain of the United States District Court for the Southern District of New York, as a judicial intern to the Honorable Bernice D. Siegal of the Queens County Supreme Court, and as a judicial intern to the Honorable Melvin L. Schweitzer of the New York County Supreme Court, Commercial Division. Ms. Ray is fluent in Ukranian and Russian. She is admitted to practice in New York. Ms. Ray has experience in contract, corporate, antitrust, commercial and securities regulations matters.

8 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 194 of 228 PageID# 11389

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: The Brualdi Law Firm, PC Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Sophia Ray OC 458.2 $300.00 $137,460.00

TOTALS 458.20 $137,460.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 195 of 228 PageID# 11390

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: The Brualdi Law Firm, PC Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $0.00 Filing / Misc. Fees $0.00 Overnight Delivery/Messengers $0.00 Photocopying $0.00 Postage $0.00 Service of Process Fees $0.00 Telephone / Fax $0.00 Transportation / Meals / Lodging $0.00 Litigation Fund Contributions $30,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $30,000.00 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 196 of 228 PageID# 11391

Exhibit A-8 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 197 of 228 PageID# 11392

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF M. STEPHEN DAMPIER IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, M. Stephen Dampier, hereby declare as follows:

1. I am a partner at the law firm of Dampier Law Firm, PC. I submit this declaration

m support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Dampier Law Firm, PC and its

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 1400. The total lodestar for my firm is $452034.00. My firm's lodestar amount includes Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 198 of 228 PageID# 11393

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $81,307.03 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $80,000.00

in contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 199 of 228 PageID# 11394

Executed this 2l51 day of April 2021 in Fairhope, Alabama

M. Stephen Dampier Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 200 of 228 PageID# 11395

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 201 of 228 PageID# 11396

Exhibit A BRIEF FIRM RESUME

The Dampier Law Firm, P.C. is a boutique litigation firm founded in 1995. The firm specializes in complex litigation on behalf of individuals and businesses. The firm has acted as Co-Lead Class Counsel and Class Counsel in numerous complex actions, including many antitrust cases, and has participated in the recovery of hundreds of millions of dollars for individuals and businesses that have been injured or wronged.

M. Stephen Dampier - Founder and Shareholder. Mr. Dampier graduated from The George Washington University (B.B.A., Accounting), Samford University's Cumberland School of Law (J.D.), and the New York University School of Law (LL.M.) in 1983, 1990 and 1991, respectively. He is licensed to practice law in Alabama, Colorado and Washington, D.C., maintaining a nationwide practice in complex litigation. Since 1995, Mr. Dampier has served as Co-lead Counsel or Class Counsel in numerous class actions and participated in numerous recoveries on behalf of class members. Some representative class actions include: Foster v. ABTCO (Hardboard Siding Class Action) (Circuit Court, Choctaw County, AL); In Re Aftermarket Filters Antitrust Litigation (USDC NDIL); In Re Autolights Antitrust Litigation (USDC CDCA); In Re Blood Reagents Antitrust Litigation (USDC EDP A); In Re Flat Glass Antitrust Litigation (USDC WDPA); Lucken v. Ultra Resources,Jnc. (Natural Gas Royalty Litigation) (USDC CO); In Re Marine Hose Antitrust Litigation (USDC SDFL); In Re Potash Antitrust Litigation (USDC NDIL); Thorpe v. State a/Colorado (Constitutional and Tax Litigation) (District Court, City and County of Denver, CO); Anderson v. Merit Energy Company (Natural Gas Royalty Litigation) (USDC CO); Moye v. Exxon Mobil Corporation (Natural Gas Royalty Litigation) (Monroe County Circuit Court, AL); Holman v. Kerr-McGee Rocky Mountain Corporation (Natural Gas Royalty Litigation) (District Court, Weld County, Colorado); In Re Polyurethane Foam Antitrust Litigation (UDSC NDOH); In re Photochromics Lens Antitrust Litigation (USDC MDFL); Holman v. Patina Oil & Gas Corporation (Natural Gas Royalty Litigation) (District Court, Weld County, CO); Frazier v. Unocal (Natural Gas Royalty Litigation) (District Court, Midland, TX); McGowin v. Texaco (Natural Gas Royalty Litigation) (Circuit Court, Mobile County, AL); McNeil & Sons, Inc. v. Unocal (Natural Gas Royalty Litigation) (Circuit Court, Mobile County, AL); Johnson v. Heilig-Meyers Corporation (Breach of Contract) (Choctaw County, AL); Wardell Family Limited Partnership v. Noble Energy, Inc., (Natural Gas Royalty Litigation) (District Court, Weld County, Colorado); Williams v. Phillips Petroleum Company (Natural Gas Royalty Litigation) (Circuit Court, Washington County, AL); Heffner v. BCBS of Alabama (ERISA) (USDC MDGA); Chamberlin v. BCBS ofAlabama (BRISA) (USDC SDAL); Holman v. Petro-Canada (Natural Gas Royalty Litigation) (USDC CO); Droegemuller v. Petroleum Development Corporation (Natural Gas Royalty Litigation) (USDC CO); and Davis v. Department ofRevenue , Commonwealth of Kentucky (Constitutional and Municipal Bond Tax Litigation) (U.S. Supreme Court). Mr. Dampier is admitted to practice in state and federal courts in Alabama, Colorado and Washington, D.C., including the U.S. District Courts for the Northern, Middle and Southern Districts of Alabama; The U.S. District Court, District of Columbia; U.S. District Court, Colorado; District of Columbia, Court of Appeals; 11 th Circuit, Court of Appeals; and the U.S. Supreme Court. He also has served on numerous public and private boards, including the Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 202 of 228 PageID# 11397

Royalty Policy Committee, U.S. Department oflnterior, State of Alabama Oil & Gas Board; and the State Health Coordinating Council.

John A. Ioannou - Of Counsel. Mr. Ioannou graduated from St. John's University in 1991 and 1994, earning his B.S. (Finance) and Juris Doctorate degrees, respectively. He is an experienced litigator, including substantial litigation experience with Motley Rice, LLC, Pomerantz, LLP, and the Office of the New York State Attorney General. Mr. Ioannou has worked extensively on complex antitrust matters and cases in virtually all phases of litigation for many years. He has conducted complex investigations and litigation concerning anti-competitive conduct by international and domestic corporations. In addition, he has litigated antitrust matters in federal and state courts. His extensive complex litigation experience includes: case investigations, obtaining statements from witnesses; informational interviews; developing and implementing case strategy; working with expert witnesses; engaging in motion and appellate practice; engaging in all phases of discovery from subpoenas and depositions to document review and e discovery; participating in mediations and settlement negotiations, approval and administration.

Vanya Dugalic-Of Counsel. Ms. Dugalic graduated from Franklin & Marshall College in Lancaster, Pennsylvania, earning her B.A. in History and Russian Language. She obtained her Juris Doctorate from Widener University School of Law in Wilmington, Delaware, in 2002. Ms. Dugalic has worked extensively on complex antitrust cases in virtually all phases since 2003. In addition to In Re: Interior Molded Doors, her antitrust litigation experience includes: In Re: OSB, In Re: Blood Reagents, In Re: Automobile Parts, and In Re: Local TV Ads. In addition to motion practice, Ms. Dugalic has developed and investigated antitrust cases from the onset of the litigation. She has litigated matters in federal and state courts, having substantial e-discovery and document review experience in antitrust matters. She is experienced in mahy types of investigations from antitrust litigation to complex factoring transactions. She also focuses on depositions, witness statements and interviews. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 203 of 228 PageID# 11398

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: The Dampier Law Firm Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar M. Stephen Dampier P 112.4 $ 585.00 $65,754.00 John A. Ioannou OC 797.3 $ 300.00 $239,190.00 Vanya Dugalic OC 490.3 $ 300.00 $147,090.00

TOTALS 1,400.0 $452,034.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 204 of 228 PageID# 11399

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: The Dampier Law Firm Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees Overnight Delivery/Messengers Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $1,307.03 Litigation Fund Contributions $80,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $81,307.03 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 205 of 228 PageID# 11400

Exhibit A-9 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 206 of 228 PageID# 11401

IN THE UNITED ST ATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: l 8-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF MARCH. EDELSON IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE A WARDS TO THE CLASS REPRESENTATIVES

I, Marc H. Edelson, hereby declare as follows:

1. I am a partner at the law firm of Edelson & Associates, LLC. I submit this

declaration in support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Edelson & Associates and its

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 1,012.20. The total lodestar for my firm is $383,255. My firm's lodestar amount Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 207 of 228 PageID# 11402

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm's attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm's contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm's lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $75,075 in unreimbursed

costs and expenses in this litigation through March 31, 2021, including $75,000 in contributions

to the Indirect Purchaser Plaintiffs' joint litigation fund. My finn advanced these costs and

expenses with no assurance that such costs and expenses would be repaid. My firm has only set

forth costs and expenses incurred through March 31, 2021, in accordance with the guidelines

established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 208 of 228 PageID# 11403

Executed this 28th day of April 2021 in Newtown, Pennsylvania.

Marc H. Edelson, Esq. Edelson & Associates, LLC 3 Terry Drive, Suite 205 Newtown, PA 18940 (215) 867-2399 medelsc [email protected] Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 209 of 228 PageID# 11404

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 210 of 228 PageID# 11405

BIOGRAPHY OF & EDELSON & ASSOCIATES, LLC

Edelson & Associates, LLC has been engaged in the practice of complex and class action

litigation since 2003. Prior to forming Edelson & Associates, LLC, Marc H. Edelson was the

founder and managing partner of Hoffman & Edelson, LLC which focused on class action

litigation exclusively since its formation in 1990.

As a partner at Hoffman & Edelson, LLC, Marc Edelson has served as lead counsel or as

a member of the Executive Committee in numerous important cases including:

ln re Pharmaceutical lndust1y Average Wholesale Pr.ice Litigation: MDL 1456, Civil Action No. 01-CV-12257, United States District Court for the District of Massachusetts (co-lead counsel)

ln re Copper Antitrust Litigation: MDL Docket No. 1303 United States District Court for the Western District of Wisconsin (member of executive committee)

In re Western States Wholesale Natural Gas Antitrust Litigation, MDL-1566, Civil Action No. 2:03-cv-01431 United States District Court for the District of Nevada (co lead counsel)

In re Ciprofloxacin Hydrochloride Antitrust Litigation MDL-001383, United States District Court Eastern District of New York (co-lead counsel)

In re Premarin Antitrust Litigation Civil Action No. 1:01cv447 United States District Court for the Southern District of Ohio Western Division at Cincinnati (co-lead counsel)

Elizabeth Blevins v. Wyelh-Ayerst Laboratories, Inc., No. 324380, Superior Court of the State of CA, County of San Francisco ( co-lead counsel)

Denise Roberts v. Fleet Bank (RI), National Association and Fleet Credit Card Services, L.P., Civil Action, No. 00-CV-6142.

1 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 211 of 228 PageID# 11406

In the United States District Court for the Eastern District of PA United States Court of Appeals for the Third Circuit, No. 01-442 (co-lead counsel)

Jason Tesauro and E lizabeth Eley v. The Quigley Corporation, No. 00-1011, Philadelphia County, Court of Common Pleas (co-lead counsel)

Lyndah Wise v. Union Acceptance Corporation, No. 01-C-8479 United States District Court for the Northern District of Illinois ( co-lead counsel)

Rudi Rodriguez v. Ford Motor Credit Company, Case No. 01-C 8526 United States District Court for the Northern District of Illinois ( co-lead counsel)

Joseph and Cynthia Papa v. General Electric Capital Mortgage Services, Inc. Superior Court of New Jersey, Camden County, Docket No. L-5311-97 (co-lead counsel)

Renee C. Pegram et al. v. Beneficial Corp .. Superior Court of New Jersey-Law Division-Camden County, Docket No. L-8308-97 (co-lead counsel)

Karen and Barry Gartland v. Beneficial Corp., Beneficial Management Corp. Of America, and Beneficial Consumer Discount Company. Court of Common Pleas, Philadelphia County, No. 1535 (co-lead counsel)

Eric Schonning v. A bit (USA) Computer Cmporation, Superior Court of the State of California, County of Alameda, Case No. RGO3109308 ( co-lead counsel)

Edelson & Associates, LLC has served as lead counsel in the following cases:

New England Carpenters Health Benefits Fund et al. v. First DataBank. Inc. and Mckesson Corp., Civil Action No. I :05-cv-11148. United States District Court for the Dist1·ict of Massachusetts (settled for $350 million) (co-lead counsel)

Electronic Connections Services, Corp. v. MSI Computer Corp., et al., Superior Court of the State of California, County of Los Angeles. Case No. BC316232 (settled) (lead counsel)

Eric Schonning v. Jetway Computer Corp .. Superior Court State of California, County of Alameda, Case No.: RG0S-214870 (settled) (lead counsel)

Electronic Connection Services Corp. v. MSI Computer Corp., Superior Court of the State of California, County of Los Angeles, Case No.: RG316232 (settled) (lead counsel)

Gerald J. Normandin. Jr. v. Soyo Group, Inc., Superior Court of the State of California, County of San Bernandino, Rancho Cucomonga, Case No.: RCV082128 (settled) (lead counsel)

2 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 212 of 228 PageID# 11407

In Re HELOC Minimum Payment Calculation Litigation, Case No. l 5-cv-00267, United States District Court Eastern District of Pennsylvania (settled) (co-lead counsel)

Edelson & Associates, LLC has served on the Executive Committee of the following

cases:

In re Certainteed Corp. Roofing Shingle Product Liability Litigation, United States District Court Eastern District of Pennsylvania, MDL Docket No. 1817 (settled)

In re HP Inkjet Printer itigation, United States District Court Northern District of California (San Jose Division) Case No.: C053580JF (settled)

In addition to the above, Edelson & Associates, LLC is involved in numerous other cases

in which it has no defined official title.

Marc H. Edelson is the founder of Edelson & Associates, LLC. Mr. Edelson is a

graduate of The Wharton School of The University of Pennsylvania (B.S. 1984 cum laude) and

The University of California, Los Angeles School of Law (J.D. 1987). Mr. Edelson is admitted

to practice in New York (admitted 1988) and Pennsylvania (admitted 1988).

Liberato P. Verderame is the senior associate at Edelson & Associates, LLC. Mr.

Verderame attended Villanova University (B.A., 1994) and Villanova University School of Law

(J.D., 1997). Since then he has litigated cases in Federal Courts nationwide and has litigated

successful appeals in both Pennsylvania's Commonwealth and Superior Courts and New Jersey's

Appellate Division.

Since joining Edelson and Associates in 2005, he has represented plaintiffs in several

national class action cases including:

In Re: Generic Pharmaceuti als Pricing Antitrust Litigation, MDL No. 2724 (E.D. Pa.)

3 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 213 of 228 PageID# 11408

Pharmaceutical Industry Average Wholesale PJice Litigation. MDL No. 1456 (D. Mass.)

In Re: Refrigerant Compressors Antjtrust Litigation, MDL 2042 (E.D. Mich.)

In Re: Western Areas Wholesale Natural Gas Antitrust Litigation, MDL-1566 (D. Nev.)

In Re: Yahoo! Litigation, 06-cv-2737 (C.D. Cal.)

Kent v. Hewlett-Packard Company, 5:09-cv-05341 (N.D. Cal.)

New England Carpenters Health Benefits Fund v. First Databank, Inc., 1 :05-cv-11148 (D.

Mass.)

OSB Antitrust Litigation, 06-CV-00826 (E.D. Pa.)

In re Certainteed Corp. Roofing Shingle Product Liability Litigation, MDL Docket No.

1817 (E.D. Pa.)

Morris v. ADT Security Services, Inc., No. 07-cv-80950 (S.D. Fla.)

Nygren et al. v. Hewlett-Packard Company, No. 07-5793 (N.D. Cal.)

and

Leeds v. IKO Manufactming. Inc., No: 2: 17-cv-00339 (E.D. Pa.).

Mr. Verderame also represents individual plaintiffs with regard to insurance coverage,

breach of contract and bad faith claims, personal injury and other matters. He serves as lead trial

counsel and recently obtained a jury verdict which was the largest insurance coverage claim

reported in VerdictSearch, Pennsylvania, during 2016.

Sati Gibson is an associate at the firm since 1999. Ms. Gibson attended Oberlin College

(B.A. 1999) and Boston College School of Law (J.D. 2002). Ms. Gibson concentrates her

practice in antitrust and consumer matters.

4 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 214 of 228 PageID# 11409

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Edelson & Associates, LLC Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Edelson, Marc P 109.80 $ 800.00 $87,840.00 Edelson, Marc P 12.80 $ 850.00 $10,880.00 Edelson, Marc P 2.00 $ 900.00 $1,800.00 Verderame, Liberato A 19.10 $ 600.00 $11,460.00 Verderame, Liberato A 33.00 $ 625.00 $20,625.00 Washington, Zakiya A 835.50 $ 300.00 $250,650.00

TOTALS 1012.20 $383,255.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 215 of 228 PageID# 11410

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Edelson & Associates, LLC Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees $75.00 Overnight Delivery/Messengers Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging Litigation Fund Contributions $75,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $75,075.00 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 216 of 228 PageID# 11411

Exhibit A-10 Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 217 of 228 PageID# 11412

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF JOHN G. EMERSON IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE A WARDS TO THE CLASS REPRESENTATIVES

I, John G. Emerson, hereby declare as follows:

1. I am the owner of the law firm, Emerson Firm, PLLC. I submit this declaration in

support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees, Reimbursement

of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Emerson Firm, PLLC and its

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 69.20. The total lodestar for my firm is $48,038.00. My firm's lodestar amount includes Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 218 of 228 PageID# 11413

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $18,315.38 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $15,000.00

in contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 219 of 228 PageID# 11414

9. I declare under penalty of pe1jury that the foregoing is true and correct.

Executed this 21st day of April, 2021 in Houston, Texas. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 220 of 228 PageID# 11415

Exhibit A Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 221 of 228 PageID# 11416

EXHIBIT A

Emerson Firm, PLLC Houston Attorneys at Law Little Rock

Class Action Litigation Antitrust Litigation Securities Litigation ERISA Litigation Consumer Litigation Trials and Appeals Personal Injury and Wrongful Death Martindale-Hubble Rated AV Preeminent

Our Firm

Emerson Firm, PLLC (“EF”) has a national class action legal practice with offices in Houston, Texas, and Little Rock, Arkansas.

The Firm and its team of experienced attorneys and paralegals handles complex commercial litigation with a concentration on cases that involve violations of federal antitrust statutes, violations of federal and state consumer protection laws, securities laws, and violations of the Employee Retirement Income Security Act of 1974 (“ERISA”). EF has prosecuted numerous antitrust class action cases, consumer class action cases, securities fraud, and shareholder derivative cases representing consumers, damaged companies, and investors around the country and abroad. EF and its predecessor firms have been active in many class action and individual cases of note. In class action litigation, EF and its predecessor firms have represented plaintiffs in well over 100 class action or other complex litigation cases.

In antitrust, EF is currently a member of the Plaintiffs’ Counsel Steering Committee in the Aluminum Warehousing Antitrust Litigation representing first level purchasers in this Multi- District Litigation (“MDL”), 13 MDL 2481 (KBF), which is pending in the Southern District of New York and is about to be appealed to the U.S. Court of Appeals for the 2nd Circuit for the second time. EF has represented plaintiffs in the Compact Disc Antitrust Litigation filed against the music industry in the United States, and plaintiffs in the High-Pressure Laminates Antitrust Litigation in the direct purchaser case. EF has been or is currently involved in the following antitrust cases: Lithium Ion Batteries Antitrust Litigation, CRT (Cathode Ray Tube) Antitrust Litigation, Flash Memory Antitrust Litigation, GPU (Graphics Processing Units) Antitrust Litigation, Ocean Shipping Antitrust Litigation, TFT-LCD (Flat Panel) Antitrust Litigation, Trans- Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 222 of 228 PageID# 11417

Pacific Airline Surcharge Litigation, Domestic Airlines Antitrust, Liquid Aluminum Sulfate Antitrust Litigation, Bridgestone Anti-Vibration Rubber Parts Antitrust Litigation, Hard Disk Drive Antitrust Litigation, Telescopes Antitrust Litigation, and Crop Inputs Antitrust Litigation among other cases.

In privacy and data breach, EF was actively involved prosecuting cases for aggrieved consumers in the following MDL cases: In re: Anthem Healthcare Data Breach Litigation, MDL No. 2617 (N.D. Cal.); In re: Premera Healthcare Data Breach Litigation, (D. OR.) MDL No. 2633; In re: Medical Informatics Engineering Data Breach Litigation, MDL No. 2667 (N.D. Ind.); In re: Office of Personnel Management Data Breach Litigation (D.D.C.) MDL No. 2664; In re: Experian Data Breach Litigation (C.D.CA.) MDL No. 2676 in which nearly half of the named plaintiffs in the consolidated amended complaint were clients of Mr. Emerson and In re: Vizio, Inc., Consumer Privacy Litigation (C.D.CA.). Mr. Emerson’s firm was also actively involved in prosecuting two data breach cases in Arizona, In re: Banner Health Data Breach Litigation and In re: Valley Anesthesiology Data Breach Litigation. Mr. Emerson currently represents eight of the ten named plaintiffs in a Fintech privacy case against Yodlee and Envestnet. Mr. Emerson represents numerous Capital One customers in the data breach case, IN RE: Capital One Consumer Data Security Breach Litigation, (E.D.VA.), MDL No. 2915 and in IN RE: EQUIFAX, INC., Customer Data Security Breach Litigation (N.D. GA.), MDL 2800.

In consumer protection, EF currently represents numerous corn farmers in the United States in consolidated actions in the MDL In re: Syngenta AG MIR162 Corn Litigation (MDL 2591) pending before Judge John W. Lungstrum in the District of Kansas. In September 2016, this case was certified as a national class and eight states had classes certified including the state of Arkansas where EF represents the designated Arkansas bellwether trial plaintiff and many other Arkansas corn farmers. The Syngenta settlement of approximately $1.5 billion has been approved by the Court. Mr. Emerson also represents many mothers in cases involving alleged toxic baby foods containing heavy metals. These cases involve defendants Gerber, Plum, Beech-Nut, and Hain Celestial. Mr. Emerson represents owners of Nissan Rogue vehicles in cases against Nissan regarding the Nissan CVT transmission, owners of Toyota vehicles in the Toyota Hybrid Brake Litigation, and owners of certain Subaru vehicles with alleged sudden acceleration problems. Mr. Emerson was a leader in the MDL baby bottle action captioned In Re: Bisphenol-A (BPA) Polycarbonate Plastic Products Liability Litigation in the United States District Court for the Western District of Missouri. Mr. Emerson was Co-Lead Counsel in the Webb et al. v. Carters Inc. et al. class action litigation in the United States District Court for the Central District of California concerning Carter’s line of tag-less baby clothing and in Montanez et al. v. Gerber Childrenswear, Inc., et al., a class action which settled in the United States District Court for the Central District of California concerning Gerber’s line of tag-less baby clothing. EF currently represents numerous Texas energy consumers in the District Court of Harris County, Texas allegedly damaged by the negligence and gross negligence of Energy Reliability Council of Texas, Inc. (“ERCOT”) during the severe winter storm in February 2021.

Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 223 of 228 PageID# 11418

EF’s predecessor firm represented numerous long-grain rice farmers in Arkansas and other states, in the MDL action In re: Genetically Modified Rice Litigation (the “Rice MDL Action”). The Rice MDL Action sought damages for long-grain rice producers in Arkansas, Missouri, Mississippi, Louisiana, and Texas for defendants’ contamination of the United States’ rice supply with genetically modified rice as revealed by Bayer and the USDA in August 2006. This MDL action was settled for over $750 million in cash relief for American rice farmers.

The Firm has been active in prosecuting cases seeking to improve corporate governance in public companies through its involvement in shareholder derivative litigation. Most notably, John Emerson, served as Co-Lead Counsel in cases resulting in significant and far-reaching corporate governance and compliance improvements within companies such as AOL/Time Warner, Computer Associates, Nicor, Cryolife, Inc., and Crompton (Chemtura). The Firm has also represented shareholders in claims involving corporate buyouts and other change-of-control transactions.

Finally, John Emerson of EF served on the Enron ERISA Litigation Plaintiffs’ Counsel Steering Committee. This case settled in the United States District Court, Southern District of Texas, Houston Division in 2005.

Mr. Emerson was born in Little Rock, Arkansas, and was raised there and in Houston, Texas. He is a member of the state bars of Texas, Washington and Arkansas. Mr. Emerson obtained his Bachelor of Arts degree from the University of Texas at Austin in 1973 and then earned his Juris Doctorate degree from South Texas College of Law Houston in 1980. He is a Life Member of the UT alumni group, Texas Exes. Mr. Emerson has been rated “AV Preeminent” for the last 20 years by Martindale-Hubbell. This is the highest possible peer review rating in legal ability and ethical standards. Mr. Emerson was honored by being named one of the Top 100 Trial Lawyers in America by the National Trial Lawyers from 2013 through 2020.

In his antitrust practice, Mr. Emerson is a member of the Plaintiffs’ Counsel Steering Committee in the Aluminum Warehousing Antitrust Litigation representing his client and named plaintiff from Arkansas, Claridge Products, and other first level purchasers in this MDL, 13 MDL2481 (KBF). The case has been remanded to the trial court in the Southern District of New York after Mr. Emerson’s team won the appeal of the case before the U.S. Court of Appeals for the 2nd Circuit on the issue of antitrust standing. Mr. Emerson has represented plaintiffs in the Compact Disc Antitrust Litigation filed against the music industry in the United States, and plaintiffs in the High-Pressure Laminates Antitrust Litigation in the direct purchaser case. Notably, Mr. Emerson also has been or is currently involved in the following antitrust cases: Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 224 of 228 PageID# 11419

Lithium Ion Batteries Antitrust Litigation, CRT (Cathode Ray Tube) Antitrust Litigation, Flash Memory Antitrust Litigation, GPU (Graphics Processing Units) Antitrust Litigation, Ocean Shipping Antitrust Litigation, TFT-LCD (Flat Panel) Antitrust Litigation, Trans-Pacific Airline Surcharge Litigation, Domestic Airlines Antitrust Litigation, Liquid Aluminum Sulfate Antitrust Litigation, and the Bridgestone Anti-Vibration Rubber Parts Antitrust Litigation case, among others.

In his privacy and data breach practice, Mr. Emerson is actively involved prosecuting cases for aggrieved consumers in the following pending or settled MDL privacy or data breach cases: IN RE: Marriott International, Inc., Customer Data Security Breach Litigation, MDL No. 2879 (Dist. MD.); IN RE: EQUIFAX, INC., Customer Data Security Breach Litigation, MDL No. 2800 (N.D. GA.); In re: Anthem Healthcare Data Breach Litigation, MDL No. 2617 (N.D. Cal.); In re: Premera Healthcare Data Breach Litigation, (D. OR.) MDL No. 2633; In re: Medical Informatics Engineering Data Breach Litigation, MDL No. 2667 (N.D. Ind.); In re: Office of Personnel Management Data Breach Litigation (D.D.C.) MDL No. 2664; In re: Experian Data Breach Litigation (C.D.CA.) MDL No. 2676, and In re: Vizio, Inc., Consumer Privacy Litigation (C.D.CA.). He is also has been actively involved in prosecuting two Arizona data breach cases, In re: Banner Health Data Breach Litigation and In re: Valley Anesthesiology Data Breach Litigation. Mr. Emerson also a case involving the Capital One data breach which will most likely go into Multi District Litigation.

In his consumer class action practice, Mr. Emerson represents numerous corn farmers in the United States in consolidated actions in the case In re: Syngenta AG MIR162 Corn Litigation (MDL 2591). A global settlement of approximately $1.5 billion has been Court approved. Mr. Emerson is currently prosecuting numerous class actions around the U.S. on behalf of contractors, farmers, and individual consumers relating to allegedly defective “303” hydraulic tractor oil fluid. Mr. Emerson has represented policyholders in cases against Transamerica and Lincoln Life concerning increased cost of insurance rates, COI, and/or increased monthly deductions. Mr. Emerson served as Chairman of the Expert Witness Committee in the consolidated MDL action styled In Re: Bisphenol-A (BPA) Polycarbonate Plastic Products Liability Litigation filed in the United States District Court for the Western District of Missouri. Mr. Emerson represented one of the named lead plaintiffs in the AOL Version 5.0 Software Litigation. He was Co-Lead Counsel for a many parents in the Gerber’s baby clothing litigation and the Carter’s baby clothing litigation. Both cases resolved for plaintiffs in 2013. Mr. Emerson was a consultant to Canadian plaintiffs’ counsel in the Canadian Medtronic Pacemaker Pacing Lead Product Liability Litigation that was certified and settled in British Columbia as a Canadian national class action. He has been a consultant to Canadian counsel in the Canadian Compact Disc Antitrust Litigation, the Canadian Publishers Clearing House Litigation, and the Canadian AOL 5.0 Software Litigation.

In his retirement plan practice, Mr. Emerson was appointed to the Plaintiffs’ Counsel Steering Committee by Judge Melinda Harmon, United States District Judge, Southern District of Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 225 of 228 PageID# 11420

Texas – Houston Division, in the consolidated Enron ERISA Litigation, styled Pamela M. Tittle v. Enron Corp., et al.

In his corporate practice, Mr. Emerson has represented numerous stockholders in shareholder derivative lawsuits brought against corporate boards alleging breaches of fiduciary duties. These suits sought to impose corporate governance reforms aimed at protecting shareholders and eliminating corporate waste and abuse. In the past, Mr. Emerson served as Co- Lead counsel in the Computer Associates shareholder derivative action in the Federal District Court for the Eastern District of New York. This action was brought against the Computer Associates’ board of directors and led to the resignation of the Company's CFO, the resignation of two other senior financial officers, and the adoption of certain corporate governance measures that Computer Associates has since represented as the "gold standard" of governance reform. Mr. Emerson was Co-Lead Counsel in the case styled In Re: Nicor, Inc. Shareholder Derivative Litigation in the Circuit Court of Cook County, Illinois County Department, Chancery Division. This action was brought against Nicor's board of directors and its settlement resulted in major corporate governance improvements at Nicor. Mr. Emerson was Co-Lead Counsel in the case styled In Re: Cryolife Derivative Litigation pending in the Superior Court of Fulton County, Georgia. The settlement of this action resulted in wide-sweeping corporate governance improvements at Cryolife. Mr. Emerson was also Co-Lead Counsel in the case styled In re: AOL Time Warner Shareholder Derivative Litigation which was settled in the Federal District Court for the Southern District of New York. This settlement resulted in wide ranging corporate governance and compliance changes and was officially recognized as a substantial factor in Time Warner’s ability to obtain $200 million from its Directors’ and Officers’ (D&O) insurance carriers. Mr. Emerson was Lead Counsel in the action styled In re: Crompton (now known as Chemtura) Shareholder Derivative Litigation which settled with Crompton’s D & O carrier, AIG, at JAMS in New York and was thereafter approved by the Bankruptcy Court for the Southern District of New York. This settlement resulted in major corporate governance improvements.

Mr. Emerson was admitted to the Texas Bar in June, 1980. He is admitted to practice before the U.S. Supreme Court; U.S. Court of Appeals for the 2nd, 5th, and 8th Circuits; U.S. District Courts for the Northern, Southern, Eastern, and Western Districts of Texas; Eastern and Western Districts of Arkansas; Western District of Washington; District of Colorado; Eastern District of Michigan; and all Texas, Washington, and Arkansas state courts.

Mr. Emerson has extensive jury trial experience over the past 40 years. He is a member of the legal fraternity Delta Theta Phi. He is also a member of The National Trial Lawyers; American Association for Justice (“AAJ”); AAJ Class Action Litigation Group; Fellow of The Pound Civil Justice Institute; Texas Trial Lawyers Association; American Bar Association (Tort and Insurance Practice and Legal Economics Sections); State Bar of Texas (Grievance Committee 4-D, Houston, 1991-94); Membership Services Committee, 1991-92); Sustaining Life Fellow Texas Bar Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 226 of 228 PageID# 11421

Foundation; Bar Association for the United States District Court for the Eastern District of Texas; Houston Bar Association; Fellow of the Houston Bar Foundation; Washington State Bar; King County Bar Association; Arkansas Trial Lawyers Association; Pulaski County Bar Association; and the Arkansas Bar Association. Mr. Emerson was honored by the Governor of Arkansas when he was named an Arkansas Traveler, an Ambassador of Good Will on behalf of the people of the state of Arkansas to people everywhere.

Mr. Emerson is married with two grown children, three grandsons, and three rescued dachshunds. He has always enjoyed the outdoors and has hunted and fished throughout the United States, British Columbia, Canada, Mexico, Honduras, Uruguay, Argentina, Botswana, and South Africa. He is a member of Ducks Unlimited and is a life member of Safari Club International.

Mr. Emerson’s email address is [email protected]. Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 227 of 228 PageID# 11422

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust

Firm Name: Emeson Firm, PLLC Reporting Period: Inception through February 28, 2021

Historical Total Hourly Total Name Status Hours Rate Lodestar Emerson, John P 56.40 $795.00 $44,838.00 Autry, Tanya PL 12.80 $250.00 $3,200.00

TOTALS 69.2 $48,038.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-2 Filed 05/03/21 Page 228 of 228 PageID# 11423

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Emerson Firm, PLLC Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $0.00 Filing / Misc. Fees $0.00 Overnight Delivery/Messengers $0.00 Photocopying $25.50 Postage $4.05 Service of Process Fees $0.00 Telephone / Fax $0.00 Transportation / Meals / Lodging $3,285.83 Litigation Fund Contributions $15,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $18,315.38 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 1 of 253 PageID# 11424

Exhibit A-11 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 2 of 253 PageID# 11425

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: l 8-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF PETER M. FISHER IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN A WARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES .

I, Peter M. Fisher, hereby declare as follows:

1. I am the owner and sole attorney of Fisher Law Office, PLLC. I submit this

declaration in support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of the Fisher Law Office 1s

summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorney and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 26.2. The total lodestar for my firm is $5,940.00 My firm's lodestar amount includes Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 3 of 253 PageID# 11426

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm's attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm's contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm's lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 26th day of April 2021 in Fort Myers, Lee County, Florida.

Peter M. Fisher, Esq.

SWORN TO and subscribed before me,;lSy Peter M. Fisher, Esq, who_ ~N2·uced a Florida Driver's License as identification or _V_ iiis personally known to me on this ~ ay of April 2021 .

.-· ti!i5,;i;:•.... JUANITA REYNA {f~~~\ Notary Public • State of Florida \~Wl! Commission # GG 238402 ary Public, State of Florida ··•.'-:f oF r.'rt-..- My Comm. Expim Jul 15, 2022 · ..... Bonded through Nation•! Notary Assn. My Commission Expires: 7/ls:{:?r Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 4 of 253 PageID# 11427

EXHIBIT A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 5 of 253 PageID# 11428

f ISHER LAW OFFICE

ATTORNEY AT LAW

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 6 of 253 PageID# 11429

PETER M. FISHER | BUSINESS & CONSTRUCTION LAW ATTORNEY Phone: (239) 275-2239 Fax: (239) 790-1358 Email: [email protected]

Attorney Peter M. Fisher is committed to serving business owners, contractors, and residents in Fort Myers, Cape Coral, Punta Gorda and surrounding areas. Peter Fisher provides advice and advocacy in the areas of business law, construction law, employment law, and civil lawsuits. Peter’s mission is to provide his clients with thoughtful, creative, and cost-effective legal solutions to their business and employment-related legal issues.

With over 10 years of legal experience in two states, Peter has helped everyone from homeowners to contractors, as well as investors and business owners, to resolve contract issues, construction-related disputes, and employment concerns. He makes it a priority to devote the time, care, and attention necessary to meet his client's needs. Peter is an alumni of Florida Atlantic University, graduating summa cum laude with a Bachelor's Degree in Marketing in 2007. He then obtained his Juris Doctorate (J.D.) from Northeastern University School of Law in 2010. He was licensed to practice in Massachusetts in 2010, and then in Florida in 2016.

Throughout his career, Peter has worked with business owners and individuals, representing them in State and Federal court and in administrative proceedings, and helping them with resolutions to their toughest construction disputes. Most recently, Peter worked as an Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 7 of 253 PageID# 11430

Associate Attorney for the Law Office of Kevin F. Jursinski. P.A., before leaving to found Fisher Law Office, PLLC, in 2018.

Fisher's connection to the Fort Myers, FL area runs deep. Before becoming an attorney, he was a professional baseball player from 1998 to 2005. After he was drafted in the fourth round by the Minnesota Twins, he played for the local minor-league team, the Fort Myers Miracle. His wife is also a Fort Myers native. After Peter's legal career took him to Massachusetts, Peter and his family were eager to return home to Southwest Florida, where he opened his own practice in 2018.

Peter has multi-state experience, maintaining licenses to practice in both Florida and Massachusetts, and continues to represent clients in Massachusetts through an Of Counsel affiliation with Goldman Law Group. Working in both State and Federal courts, Peter represents clients in construction, business, and employment-related matters, from the U.S. District Court to local administrative and licensing agencies.

Attorney Peter Fisher is committed to putting his clients' needs first. He'll be there when you need him at the negotiating table, in front of administrative agencies, or in court.

Peter M. Fisher, At A Glance Bar & Court Admissions

• United States District Court, Middle District of Florida, 2018 • Florida Bar, 2016 • Lee County Bar Association, 2016 • Massachusetts Bar Association, 2010 • United States District Court, District of Massachusetts, 2012 Education

• Northeastern University School of Law, J.D., 2010 • Florida Atlantic University, B.A. in Marketing, 2007

Legal Experience

• Fisher Law Office, PLLC, Fort Myers, Florida, Owner, 2018-Present • Goldman Law Group, Newton, Massachusetts, Of Counsel, 2018-Present • Law Office of Kevin F. Jursinski & Associates, Fort Myers, Florida, Associate Attorney, 2016-2017 • Goldman Law Group, Newton, Massachusetts, Attorney, 2014-2016 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 8 of 253 PageID# 11431

• Rosen Law Office, P.C., Andover, Massachusetts, Associate, 2011-2014 • Philips Lighting, Contract Attorney, 2011 • Prince, Lobel Glovsky & Tye, LLP, Law Clerk, 2010 • Kotin, Crabtree & Strong, Law Clerk, 2009 • Massachusetts Division of Capital Asset Management, Office of the General Counsel, Boston Massachusetts, Legal Intern, 2009 • United States Court of Appeals, First Circuit, Boston, Massachusetts, Judicial Intern, 2008

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 9 of 253 PageID# 11432

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Fisher Law Office, PLLC Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Peter M. Fisher, Esq. P 18.20 $300.00 $5,460.00 Juanita Reyna PL 8.00 $60.00 $480.00

TOTALS 26.20 $5,940.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 10 of 253 PageID# 11433

Exhibit A-12 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 11 of 253 PageID# 11434

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF MICHAEL G. SIMON, ESQ. IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN A WARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Michael G. Simon, Esq., hereby declare as follows:

l. I am a partner at the law firm of Frankovitch, Anetakis, Simon, Decapio & Pearl

LLP. I submit this declaration in support of Indirect Purchaser Plaintiffs' Motion for an Award of

Attorneys' Fees, Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Frankovitch, Anetakis, Simon,

Decapio & Pearl LLP and its attorneys are summarized in the firm resume attached hereto as

Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel . This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

1 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 12 of 253 PageID# 11435

28, 2021 is 16.9. The total lodestar for my fi rm is $5,840.00. My firm's lodestar amount includes

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm's attorneys and professional staff are the same as the usual and cllstomary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm's contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in m y firm's lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $5,000.60 in unreimbursed

costs and expenses in this litigation through M arch 31, 202 1, including $5,000.00 in contributions

to the Indirect Purchaser Plaintiffs' joint litigation fund. My firm advanced these costs and

expenses with no assurance that such costs and expenses would be repaid. My firm has only set

forth costs and expenses incurred through March 31, 202 1, in accordance with the guidelines

established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incun-ed. These

expenses were reasonably and necessarily incurred in connection with this litigation.

2 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 13 of 253 PageID# 11436

9. I declare under penalty of pe1jury that the foregoing is true and correct.

Executed this 29th day of April 2021 in Weirton, West Virginia. -7 · /l LI/i ·l~v , MICHAEL G. SIMON, ESQ.

3 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 14 of 253 PageID# 11437

EXHIBIT A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 15 of 253 PageID# 11438

Exhibit A FRANKOVITCH, ANETAKIS, SIMON, DECAPIO & PEARL, LLP 337 Penco Road Weirton, West Virginia 26062 (304) 723-4400 Fax (304) 723-5892 www.faslaw.com

Curriculum Vitae

Partners: Carl N. Frankovitch, M. Eric Frankovitch, Michael G. Simon, Thomas J. Decapio, Kevin M. Pearl and Carl A. Frankovitch

Associates: Carson Schambach

Frankovitch, Anetakis, Simon, Decapio & Pearl , LLP, is a West Virginia based law firm with a main office in Weirton and branch offices in Wheeling and Chester, West Virginia. The fi rm is comprised of attorneys licensed in West Virginia, Ohio, and Pennsylvania. Although the firm is very diverse in its areas of practice, its main focus is litigation. The firm's litigation practice centers on the representation of injured individuals, mass litigation, and class action litigation. The firm handles in personal injmy, class actions and complex litigation, labor and employment law, insurance litigation, general civil litigation, corporate and business law, banking, real estate, healthcare, Social Security, probate, criminal law, and family law. Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 16 of 253 PageID# 11439

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Frankovitch, Anetakis, Simon, Decapio & Pearl LLP Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Simon, Michael P 16.60 $350.00 $5,810.00 Prevost, Tammie PL 0.30 $100.00 $30.00

TOTALS 16.90 $5,840.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 17 of 253 PageID# 11440

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Frankovitch, Anetakis, Simon, Decapio & Pearl LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $0.00 Filing / Misc. Fees $0.00 Overnight Delivery/Messengers $0.00 Photocopying $0.10 Postage $0.50 Service of Process Fees $0.00 Telephone / Fax $0.00 Transportation / Meals / Lodging $0.00 Litigation Fund Contributions $5,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $5,000.60 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 18 of 253 PageID# 11441

Exhibit A-13 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 19 of 253 PageID# 11442

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF BRIAN PENNY IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Brian Penny, hereby declare as follows:

1. I am a partner at the law firm of Goldman, Scarlato & Penny P.C. I submit this

declaration in support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Goldman Scarlato & Penny P.C.

and its attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 834.5. The total lodestar for my firm is $345,053. My firm’s lodestar amount includes Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 20 of 253 PageID# 11443

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $70,256.68 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $65,000 in

contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 21 of 253 PageID# 11444

Executed this 23rd day of April 2021 in Conshohocken, Pennsylvania

r () J

______

Brian Douglas Penny GOLDMAN SCARLATO & PENNY 161 Washington Street, Suite 1025 Conshohocken, PA 19428 484-342-0700 [email protected]

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 22 of 253 PageID# 11445

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 23 of 253 PageID# 11446

GOLDMAN SCARLATO & PENNY, P.C. 161 Washington Street, Suite 1025 Conshohocken, PA 19428 (484) 342-0700

GOLDMAN SCARLATO & PENNY, P.C. is a nationwide class action law firm. Our

lawyers have dedicated their careers to vindicating the rights of ordinary people and businesses

victimized by anticompetitive conduct, securities fraud, identity theft, deceptive consumer

practices, unscrupulous financial advisors, or who have suffered harm as a result of defective

medical devices and dangerous drugs. Goldman Scarlato & Penny, P.C. prosecutes securities

fraud, antitrust, and consumer fraud class actions, investor arbitrations, sexual assault cases, as

well as mass actions on behalf of those injured by defective medical devices and dangerous drugs

throughout the United States. The Firm’s lawyers have recovered hundreds of millions of dollars

on behalf of their clients and helped to institute meaningful changes in business practices that seek

to ensure robust competition in commercial markets, honest and fair disclosures in financial

markets, and truthful advertising in retail markets.

The Firm has played prominent roles in several noteworthy and ground-breaking cases.

Recently, the Firm has fought to protect those whose most sensitive and private data was

compromised in In re Anthem, Inc. Data Breach Litigation ($115 million settlement on behalf of

healthcare patients), In re Intuit Data Litigation. (member of steering committee; settled) and has

served as sole lead counsel in Athens Orthopedic Clinic, P.A. (case pending), and United Shore

Financial Services, LLC (settled). The Firm has fought to enforce the nation’s antitrust laws and

ensure a level competitive playing field in cases such as In re Air Cargo Antitrust Litigation

(settlements of over $1 billion), In re Vitamins Antitrust Litigation (settlements of over $1.7

billion), In re Brand Name Prescription Drugs Antitrust Litigation (settlements of approximately Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 24 of 253 PageID# 11447

$700 million), and Logue v. West Penn Multi-Listing Service ($2.75 million settlement on behalf

of consumers), and it successfully challenged businesses that misrepresented their products to

consumers in Mirakay v. Dakota Growers Pasta Co. (settlement valued at over $23 million). In

addition, the Firm has fought to protect investors and enforce the nation’s securities laws in cases

such as In re Broadcom Securities Litigation (settlement of $150 million), and AOL Time Warner

Securities Litigation, (settlement of over $2.5 billion for investors).

MARK S. GOLDMAN. Since 1986, Mark Goldman has concentrated his practice in many

different types of complex litigation, including cases involving violations of the federal securities

and antitrust laws and state consumer protection statutes. Mr. Goldman served as co-lead counsel

in a number of class actions brought against life insurance companies, challenging the manner in

which premiums are charged during the first year of coverage. In the antitrust field, Mr. Goldman

litigated several cases that led to recoveries exceeding $1 billion each, for the benefit of the

consumers and small businesses he represented, including In re Air Cargo Antitrust Litigation,

Case No. 06-MD-1775 (E.D.N.Y. 2016), In re Vitamins Antitrust Litigation, MDL No. 1285

(D.D.C. 1999), In re NASDAQ Antitrust Litigation, Case No. 94-cv-3996 (S.D.N.Y. 1994), and In

re Brand Name Prescription Drugs Antitrust Litigation, Case No. 94-c-897 (N.D. Ill. 1994). Mr.

Goldman represents and has represented numerous victims of identity theft seeking to hold

accountable companies that failed to protect the safety of private data maintained on their

networks, including In re Community Health Systems, Inc. Customer Data Security Breach

Litigation, 15-cv-222 (N.D. Ala. 2015), In re Anthem, Inc. Data Breach Litigation, Case No. 15-

MD-02617-LHK (N.D. Cal. 2015), In re Intuit Data Litigation, 15-cv-1778 (N.D. Cal. 2015), and

Collins et al v. Athens Orthopedic Clinic, P.A., (Athens-Clark Cty, Ga 2017). In the area of

securities litigation, Mr. Goldman played a prominent role in class actions brought under the

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 25 of 253 PageID# 11448

antifraud provisions of the Securities Exchange Act of 1934, including In re Nuskin Enterprises,

Inc. Securities Litigation, Master File No. 2:14-cv-00033 (D. Utah 2014), In Re: Spectrum

Pharmaceuticals, Inc. Securities Litigation, Case No. 2:13-cv-00433 (D. Nev. 2013), and In re

Omnivision Technologies, Inc. Litigation, Case No.: 5:11-cv-05235 (N.D. Cal. 2011). Mr.

Goldman also prosecuted a number of insider trading cases brought against company insiders who,

in violation of Section 16(b) of the Securities Exchange Act of 1934, engaged in short swing

trading, and currently represents victims of Ponzi schemes seeking to hold financial institutions

accountable for aiding and abetting the perpetrators of the schemes. Gregory v. Zions

Bancorporation, N.A., Case No. 2:19-cv-00015 (D. Utah); Chang v. Wells Fargo Bank, N.A., No.

4:19-cv- 01973 (N.D. Cal.).

Mr. Goldman earned his undergraduate degree from the Pennsylvania State University in

1981 and his law degree from the University of Kansas School of Law in 1986. He is a member

of the Pennsylvania bar.

PAUL J. SCARLATO. Paul Scarlato has concentrated his practice on the litigation of complex

class actions since 1989. He has litigated numerous cases under the securities, consumer, antitrust and

common law involving companies in a broad range of industries, and has litigated many cases

involving financial and accounting fraud.

In securities fraud cases, Mr. Scarlato was one of three lead attorneys for the class in Kaufman

v. Motorola, Inc., a securities fraud class action that settled just weeks before trial, and along with Mr.

Weinstein of his predecessor firm, was lead counsel in Seidman v. American Mobile Systems, Inc.,

(E.D. Pa.), a securities class action that resulted in a settlement for the plaintiff class again on the eve

of trail. Mr. Scarlato served as co-lead counsel in In re: Corel Corporation Securities Litigation (E.D.

Pa.). Mr. Scarlato was one of the lead lawyers in Leibovic v. United Shore Financial Services; Afzal

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 26 of 253 PageID# 11449

v. BMW of North America, LLC, and Yao Yi Liu v. Wilmington Trust Company. He serves on the

plaintiffs’ Executive Committee in Vikram Bhatia, D.D.S. v. 3M Company, Case No. 16-cv-01304

(D. Minn.), and is counsel in In re Platinum and Palladium Antitrust Litigation, Case No. 14-cv-

09391 (S.D.N.Y), In re Treasury Securities Auction Antitrust Litigation, Case No. 15-md-02673

(S.D.N.Y.), and In re Liquid Aluminum Sulfate Antitrust Litigation, Case No. 15-7827 (D.N.J.).

Mr. Scarlato graduated from Moravian College in 1983 with a degree in accounting, and

received his Juris Doctor degree from the Widener University School of Law in 1986. Mr. Scarlato

served as law clerk to the Honorable Nelson Diaz, of the Court of Common Pleas of Philadelphia

County, and thereafter as law clerk to the Honorable James T. McDermott, Justice of the Pennsylvania

Supreme Court. After his clerkships, and prior to becoming a litigator, Mr. Scarlato was a member of

the tax department of a major accounting firm where he provided a broad range of accounting services

to large business clients in a variety of industries.

Mr. Scarlato is a member of the bars of the Commonwealth of Pennsylvania and the State of

New Jersey, and those of various federal district and circuit courts.

BRIAN D. PENNY. Since joining the Firm in 2002, Mr. Penny has focused his practice

on class action litigation principally in the areas of antitrust, consumer protection and securities

fraud litigation. He was lead counsel in Mirakay v. Dakota Growers Pasta Co. (D.N.J. 2013)

(alleging false and misleading advertising of pasta products and resulting in a settlement valued at

over $23 million); Logue v. West Penn Multi-Listing Service (W.D. Pa. 2010) (alleging price-

fixing among brokers and multi-listing service and resulting in $2.75 million settlement); Allan v.

Realcomp II (E.D. Mich. 2010) (alleging price-fixing among brokers and multi-listing service and

resulting in a $3.25 million settlement); Boland v. Columbia Multi-Listing Service (D.S.C. 2009)

(alleging price-fixing among brokers and multi-listing service and resulting in a $1 million

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 27 of 253 PageID# 11450

settlement); and Robertson v. Hilton-Head Multi-Listing Service (D.S.C. 2009) (alleging price-

fixing among brokers and multi-listing service).

Mr. Penny served on the executive committees in In Re NHL Concussion Litigation (D.

Minn. 2014) (alleging league failed to protect players from known risks of concussions), and In

re: Community Health Systems, Inc., Customer Security Data Breach Litigation (N.D. Ala. 2015)

(alleging damages caused by data breach of health care records). He is on the Third Party

Discovery Committee in In re Disposable Contact Lenses Antitrust Litigation, 15-md-2626 (M.D.

Fla.), and is actively engaged as class counsel in In re: Clobetasol Cases, 16-CB-27240 (E.D. Pa.

2017) and In re Lidocaine-Prilocaine, 16-LD-27242 (E.D. Pa. 2017) where he leads the EPP

discovery team in those cases, In re Broiler Chicken Antitrust Litigation, 1:16-cv-08637 (N.D. Ill.

2016); and Bhatia v. 3M Company, 16-cv-1304 (D. Minn. 2016); In re Epipen Marketing, Sales

Practices and Antitrust Litigation, 2:17-md-2785 (D. Kan. 2016).

Mr. Penny has also prosecuted numerous securities fraud class actions over the course of

his career. He was a key member of the plaintiffs’ teams that prosecuted In re Broadcom Securities

Litigation, which resulted in a settlement of $150 million for the class, and AOL Time Warner

Securities Litigation, which resulted in a settlement of over $2.5 billion for investors. Mr. Penny

was also one of the lead attorneys representing the classes in a number of securities fraud actions

arising out of stock option backdating, including, In re Monster Worldwide, Inc. Securities

Litigation ($47.5 million settlement), In re Mercury Interactive Securities Litigation ($117.5

million settlement), In re SafeNet, Inc. Securities Litigation ($25 million settlement), Ramsey v.

MRV Communications et al. ($10 million settlement), and In re Semtech Securities Litigation ($20

million settlement).

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 28 of 253 PageID# 11451

Mr. Penny received his Bachelor of Arts degree from Davidson College, Davidson, North

Carolina, in 1997 and earned his Juris Doctor degree from Pennsylvania State University in 2000.

After graduating from law school, Mr. Penny served as law clerk to the Honorable John T.J. Kelly,

Jr., Senior Judge of the Superior Court of Pennsylvania. He has been named a Super Lawyer or

Rising Star each year since 2010. In 2015, Mr. Penny was one of four finalists for the American

Antitrust Institute’s Enforcement Award for Outstanding Antitrust Litigation Achievement by a

Young Lawyer for his work on Allen, et al. v. Realcomp Ltd., et al.

ALAN L. ROSCA. Mr. Rosca focuses his legal practice on complex financial and

commercial matters, particularly in the areas of securities litigation, investment fraud, and

international investment disputes. He often represents institutional and individual investors in

disputes with financial industry members arising out of investment fraud or misconduct. He

prosecutes claims on behalf of investors through class actions in state or federal courts, and FINRA

arbitrations. He also practices in the areas of wage-and-hour and other labor-related disputes,

whistleblower matters, and antitrust cases, with a focus on market manipulation.

Alan has been a lecturer and adjunct professor of Securities Regulation at Cleveland-

Marshall College of Law, Cleveland State University since 2012.

Alan has served as co-lead counsel, or is currently involved in a leading role, in class

actions on behalf of investors who lost money as a result of alleged investment fraud or Ponzi

schemes, as well as in other class action matters arising out of wage-and-hour or business disputes,

including Hanson v. Berthel Fisher & Company Financial Services, Inc., et al. (N.D. Iowa 2013)

(a securities class action on behalf of investors in an allegedly fraudulent real estate investment

program that raised approximately $26 million from investors, predicated upon the role played by

the program’s underwriter); Carol Prock v. Thompson National Properties, LLC, et al. (C.D. Cal.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 29 of 253 PageID# 11452

2013) (a securities class action on behalf of investors in an allegedly fraudulent real estate

investment program that raised approximately $17 million from the investing public, against the

program’s sponsors and promoters); Yao-Yi Liu et al. v. Wilmington Trust Company (W.D.N.Y.

2014) (a class action lawsuit on behalf of investors of a $145 million fraudulent scheme, alleging

that the defendant trustee and custodian bank breached its duties as an escrow agent and aided the

perpetrators of the scheme); Spaude v. Mysyk (N.D. Ohio 2015) (a securities class action on behalf

of investors in a $55 million allegedly fraudulent oil-and-gas investment scheme, against the

alleged perpetrators of the scheme and the law firm that assisted the scheme); Jennifer Roth v. Life

Time Fitness, Inc. (D. Minn. 2015) (a wage-and-hour class action on behalf of fitness instructors

seeking unpaid wages for work that was required by defendants); Aleem v. Pearce & Durick (D.

North Dakota 2015) (a securities class action on behalf of investors in a $65 million fraudulent

investment scheme, alleging that the defendants violated their fiduciary duties to the investors and

assisted in the scheme’s securities violations by serving as escrow agents for the investors’

investments and offering materially false opinions to the investors regarding their investments in

the scheme); Strong v. Safe Auto Insurance Group, Inc. et al. (S.D. Ohio 2016) (a wage-and-hour

class action on behalf of employees of defendants seeking unpaid wages for work that was required

by defendants); Hay v. United Development Funding IV et al. (N.D. Texas 2016) (a securities class

action on behalf of investors in a $625 million allegedly Ponzi-like real estate investment scheme,

against entities including the scheme, its principals and affiliated entities, as well as the alleged

scheme’s underwriter and auditor); Fastrich v. Continental General Insurance Company (D. Neb.

2016) (a class action on behalf of insurance agents affiliated with defendants, arising out of the

alleged non-payment of certain fees and commissions owed to such agents); Elliott v. Bank of

Oklahoma (D.N.J. 2016) (a class action on behalf of investors in a $198 million allegedly

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 30 of 253 PageID# 11453

fraudulent investment scheme perpetrated through a series of municipal bond offerings, against

the trustee bank for the bond offerings and the underwriters of some of the offerings); Ezeude v.

PayPal Holdings, Inc. et al. (N.D. Cal. 2017) (a class action lawsuit arising out of a $207 million

allegedly fraudulent Internet investment scheme that victimized over 162,000 investors

worldwide, alleging that defendants, who acted as payment processors for the scheme, facilitated

and assisted the perpetration of the scheme).

Alan received his Juris Doctor degree summa cum laude from Cleveland-Marshall College

of Law in May 2008. While in law school he served as a Managing Editor of the Cleveland State

Law Review, received the Dean's (full) scholarship for the entire Juris Doctor program, was on the

Dean's List, and won the "Best Oralist" award in the Jessup Moot Court competition, Pacific

Region. He passed the Ohio Bar exam in top 1%, with the highest grade in the state to the multi-

state (federal law) section.

He is licensed to practice law in the Ohio state and federal courts, and in other federal

courts nationwide. He has been selected to the 2017 and 2018 Ohio Super Lawyers Rising Star

list. He is a member of the Public Investors Arbitration Bar Association, the Cleveland

Metropolitan Bar Association, where he served as the Chair of the Unlicensed Practice of Law

Committee, and the Cleveland Diplomatic Corps. He also holds a Master of Business

Administration degree from Baldwin-Wallace College, Ohio. He is a speaker on Ponzi schemes,

investment fraud, cryptocurrencies, and attorney professionalism.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 31 of 253 PageID# 11454

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Goldman, Scarlato & Penny, P.C. Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Penny, Brian P 187.60 $705.00 $132,258.00 Bench, Douglas A 107.00 $475.00 $50,825.00 Orlando, Joseph, Jr. A 9.50 $300.00 $2,850.00 Biela, Robert CA 530.40 $300.00 $159,120.00

TOTALS 834.50 $345,053.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 32 of 253 PageID# 11455

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Goldman, Scarlato & Penny, P.C. Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $181.48 Filing / Misc. Fees $75.00 Overnight Delivery/Messengers $0.20 Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging Litigation Fund Contributions $65,000.00 Expert Fees $5,000.00 Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $70,256.68 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 33 of 253 PageID# 11456

Exhibit A-14 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 34 of 253 PageID# 11457

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF JOSHUA GRABAR IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Joshua Grabar hereby declare as follows:

1. I am a partner at the law firm of Grabar Law Office. I submit this declaration in

support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement

of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Grabar Law Office and its

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 639.40. The total lodestar for my firm is $201,957.50. My firm’s lodestar amount Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 35 of 253 PageID# 11458

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm’s attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm’s contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm’s lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $30,075 in unreimbursed

costs and expenses in this litigation through March 31, 2021, including $30,000 in contributions

to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these costs and

expenses with no assurance that such costs and expenses would be repaid. My firm has only set

forth costs and expenses incurred through March 31, 2021, in accordance with the guidelines

established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 36 of 253 PageID# 11459

Executed this 23rd day of April 2021 in Philadelphia, Pennsylvania.

lt--r/ ______,_.,'t Joshua H. Grabar GRABAR LAW OFFICE One Liberty Place 1650 Market Street, Suite 3600 Philadelphia, PA 19103 Tel: 267-507-6085 Fax: 267-507-6048 Email: [email protected]

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 37 of 253 PageID# 11460

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 38 of 253 PageID# 11461

One Liberty Place 1650 Market Street, Suite 3600 Philadelphia, PA 19103 Tel: 267-507-6085 Fax: 267-507-6048 www.GrabarLaw.com

FIRM RESUME

The Grabar Law Office and its principal, Joshua H. Grabar, have extensive experience as counsel in complex commercial class action litigation under state and federal antitrust laws, federal securities laws, and state consumer protection laws. Mr. Grabar has focused his practice on class action litigation since 1998.

Cases in which Mr. Grabar and the Grabar Law Office presently serve as counsel in an integral capacity include:

§ Midwest Renewable Energy, LLC v. Archer Daniels Midland Company, 2:20-cv-02212 (C.D. Ill.)

§ In re Deutsche Bank Spoofing Litigation, 20-cv-3638 (N.D. Ill.)

§ In re Robinhood Outage Litigation, 3:20-cv-01626, (N.D. Cal.)

§ In re Caustic Soda Antitrust Litigation, 1:19-cv-00385 (W.D.N.Y.)

§ In re Capital One Data Consumer Data Security Breach Litigation, 1:19-md-2915 (E.D. Va.)

§ In re Interior Molded Doors Indirect Purchaser Antitrust Litigation., 3:18-cv-00718-JAG (E.D. Va.);

§ In re Blue Cross Blue Shield Antitrust Litigation, 2:13-cv-20000 (N.D. Ala.)

§ Leeds Et. Al. V. Iko Et. Al., 2:17-cv-0039 (E.D.Pa.)

§ In re Platinum Palladium Antitrust, 14-cv-9391 (S.D.N.Y.)

§ In re Dental Supplies Antitrust, 1:16-cv-00696 (E.D.N.Y.)

§ David Kreuzer V. Qualcomm, Inc.,17-cv-526 (S.D.Cal.)

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 39 of 253 PageID# 11462

§ In re Generic Pharmaceuticals Antitrust, 2:16-md-2724-CMR (E.D.Pa.)

§ In re Treasury Securities Auction Antitrust, 15-md-2673 (S.D.N.Y.)

§ In re Equifax, Inc., Customer Data Security Breach 17-md-2800 (N.D.Ga.)

§ In re Inductors Antitrust Litigation, Case No. 5:18-cv-00198 (N.D. Cal.)

§ In re Fed Loan Servicing Litigation, Case No. 2:18-md-02833 (E.D. Pa.)

§ In re German Automotive Manufacturers Antitrust Litigation, 3:17-MD-02796, (N.D.Cal.)

§ In re Dealer Management Systems Antitrust, MDL 2817 (N.D. Ill)

§ In re Rotavirus Vaccines Antitrust Litigation, 2:18-cv-01734 (E.D.Pa.)

§ Promotional Products Antitrust - Kjessler V. Zaappaaz, Inc., 4:18-cv-00430 (S.D. Tex.)

§ In re Railway Industry Employee No-Poach Antitrust, 18-cv-798 (W.D.Pa.)

§ In re Restasis (Cyclosporine Ophthalmic Emulsion) Antitrust, 18-mc-2819 (E.D.N.Y.)

§ In re Diisocyanates Antitrust Litigation, 2:18-mc-01001 (W.D. Pa.)

§ In re Zetia Antitrust Litigation, 2:18-md-02836 (E.D.Va.)

Cases in which Mr. Grabar previously served as class counsel in an integral capacity include:

§ In re Cathode Ray Tube (CRT) Antitrust Litig., MDL 1917, 3:07-cv-05944 (N.D. Cal.). An antitrust action alleging price-fixing of cathode ray tubes and finished products containing cathode ray tubes, by the major manufacturers of these products with recoveries exceeding $224 million.

§ In re Steel Antitrust Litig., 08-cv-5214 (N.D. Ill.). An antitrust action alleging market allocation and supply restriction of steel by the world’s major manufacturers of steel with recoveries exceeding $163 million.

§ In re EPDM Antitrust Litig., MDL No. 1542 (D. Conn.). An antitrust action alleging price- fixing of Ethylene Propylene Diene Monomer with recoveries exceeding $100 million.

§ In re Hydrogen Peroxide Antitrust Litig., 05-cv-666 (E.D. Pa). An antitrust action alleging price-fixing of Hydrogen Peroxide with recoveries exceeding $97 million.

§ Alco Industries, Inc. v. DuPont Dow Elastomers, LLC, 1:04-cv-00588 (D.D.C.). An antitrust action alleging price-fixing of Polychloroprene Rubber with recoveries exceeding $36 million.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 40 of 253 PageID# 11463

§ In re Polychloroprene Rubber (CR) Antitrust Litig., 3:05-md-01642 (D. Conn.). An antitrust action alleging price-fixing of Polychloroprene Rubber with recoveries exceeding $15 million.

§ In re Methyl Methacrylate (MMA) Antitrust Litig., 2:06-md-01768 (E.D. Pa.) (recoveries exceeding $15 million).

§ In re Mercedes-Benz Antitrust Litig., 99-cv-431 (AMW) (D.N.J.) (recoveries exceeding $17 million).

§ In re Rubber Chemicals Antitrust Litig., 03-cv-1496 (N.D. Cal.) (recoveries exceeding $250 million).

Mr. Grabar advises numerous publicly listed corporations, multinational manufacturers and distributors, municipalities, universities, business owners and individuals on matters concerning antitrust compliance, retention of antitrust claims and recoveries, and consumer protection law compliance issues. Mr. Grabar advises individuals, business owners and corporations with respect to impact of antitrust claims on business valuation. Mr. Grabar also represents individual plaintiffs with regard to insurance coverage, breach of contract and bad faith claims, among other matters.

Mr. Grabar has been rated “AV Preeminent” - peer rated for highest level of professional excellence and ethical standing by Martindale-Hubble.

Mr. Grabar has been honored by his selection in 2017, 2018, 2019, 2020 and 2021 as one of Pennsylvania's Super Lawyers by Thompson Reuters' Super Lawyers publication. Each year, no more than 5 percent of the lawyers in the Commonwealth are selected to receive this honor. Mr. Grabar was previously honored to be selected in 2010 and 2013 as one of Pennsylvania's Rising Stars by Thompson Reuters' Super Lawyers publication, recognizing him as one of Pennsylvania's top up-and-coming attorneys. Each year, no more than 2.5 percent of the lawyers in the Commonwealth are selected to receive this honor. Designation as a Rising Star and a Super Lawyer is recognition that Mr. Grabar has distinguished himself with respect to his achievements as a practitioner and advocate in the eyes of the legal community in which he practices. Grabar Law Office has been honored to have been recognized as "Commercial Litigation Expert of the Year 2019 - Pennsylvania" by Acquisition International.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 41 of 253 PageID# 11464

Mr. Grabar is a graduate of the University of Pennsylvania (B.A. 1995) and the Villanova University School of Law (J.D. 1998), where he served as an Associate Editor of the Villanova Law Review. Mr. Grabar authored the publication "Antol v. Esposto: The Third Circuit Expands Preemption Under The Labor Management Relations Act," 42 Vill. L. Rev. 1995 (1997). Mr. Grabar is a member of the American Bar Association and Pennsylvania Bar Association. Mr. Grabar is a member of the International Municipal Lawyers Association and Engaging Local Government Leaders.

Julia C. Varano has extensive experience as counsel in complex commercial litigation in state and federal courts throughout the nation, with a particular concentration and emphasis in class action litigation under federal antitrust laws.

Ms. Varano works or has worked on numerous matters including In re Interior Molded Doors Indirect Purchaser Antitrust Litig., 3:18-cv-00718-JAG (E.D. Va.); In re Blue Cross Blue Shield Antitrust Litig., 2:13-cv-20000 (N.D. Al.); and In re General Motors, LLC, Ignition Switch Litigation, 14 M.D. 2543 (JMF). Ms. Varano has also worked on responses to DOJ Antitrust Division Civil Investigative Demands and DOJ Hart-Scott-Rodino Requests for Information in a pending company merger and acquisition, as well as general business litigation, and product liability litigation.

Prior to entering into private practice, Ms. Varano was the Information Management Systems Coordinator for the Superior Court of Pennsylvania, where she managed the Information Systems/IT Department including budgeting, managing inventory and contracts, and developing a content based eDiscovery compliant electronic record back-up system; served as the Deputy Prothonotary Insurance Rehabilitation & Liquidation for the Commonwealth Court of Pennsylvania, where she managed multiple complex insurance bankruptcy cases, and served as the Judicial Clerk III (Chief Clerk) to the President Judge, Hon. James G. Colins, of the

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 42 of 253 PageID# 11465

Commonwealth Court of Pennsylvania, where she supervised deputy clerks, drafted Court memos and opinions in matters within the jurisdiction of Commonwealth Court.

Ms. Varano is a graduate of the Widener University (B.A. 1980) and the Widener University School of Law (J.D. 1988). She is a member of the Pennsylvania Bar Association, the Information Governance Initiative, and Women in e-Discovery.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 43 of 253 PageID# 11466

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Grabar Law Office Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Grabar, Joshua P 7.20 $725.00 $5,220.00 Grabar, Joshua P 14.90 $775.00 $11,547.50 Varano, Julia A 617.30 $300.00 $185,190.00

TOTALS 639.40 $201,957.50

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 44 of 253 PageID# 11467

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Grabar Law Office Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees $75.00 Overnight Delivery/Messengers Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging Litigation Fund Contributions $30,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $30,075.00 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 45 of 253 PageID# 11468

Exhibit A-15 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 46 of 253 PageID# 11469

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF GREGORY F. COLEMAN IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Gregory F. Coleman, hereby declare as follows:

1. I am a partner at the law firm of Greg Coleman Law PC. I submit this declaration

in support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Coleman Law and its attorneys are

summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 559.9. The total lodestar for my firm is $197,625. My firm’s lodestar amount includes Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 47 of 253 PageID# 11470

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $52,198.54 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $50,000 in

contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 48 of 253 PageID# 11471

Executed this 3rd of May, 2021 in Knoxville, Tennessee.

______Gregory F. Coleman

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 49 of 253 PageID# 11472

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 50 of 253 PageID# 11473

I _ ,__ , GREG _,-■ COLEMAN LAW Helping People, Changing Lives

FIRM RESUME

GREG COLEMAN LAW PC A Professional Corporation First Tennessee Plaza 800 S. Gay Street, Suite 1100 Knoxville, TN 37929

gregcolemanlaw.com · Phone: 865-247-0080 · Fax: 865-522-0049 Page | 1 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 51 of 253 PageID# 11474

TABLE OF CONTENTS

The Firm 3

Practice Areas 3

Representative Cases 4

Our Team In this Case 7

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THE FIRM

Greg Coleman Law PC is an AV rated, full-service plaintiffs’ law firm composed of a carefully assembled, talented group of 13 attorneys with sound judgment, exceptional skills, and broad expertise. The firm's goal is simple: provide high quality legal services with innovative and progressive approaches to the law. To this end, the firm's attorneys recognize the importance of courtroom experience at all levels and the value of a diverse legal practice. Above all else, it is our commitment to aggressively fight for the rights of our clients that sets the firm apart.

OUR ACCOLADES

AVG' PREEMINEr-lf ~ Mo rl indelC!,• ► ltlbl)e ll ' Lewyer Ratlnga LCA~ Ll1'1GAr lON CO NSU o rAMll.lClr, 10 BEST LAW FIRM FE L LOW ·· • CUIIITSAl1$1AC!ION •·· A llll.T1Cafl ln\lllUICllf

Best Lawyers· ctrvviBN Super Lawyers

PRACTICE AREAS

 Class Actions  Dangerous Drugs & Medical Devices  Consumer Protection/Consumer Rights  Fraud/Misrepresentation  ERISA Litigation  Securities Litigation  False Advertising  FLSA Litigation  Multi-District Litigation/Mass Actions  Auto, Trucks & Motorcycle Accidents  Federal and State Appeals  Insurance Coverage Disputes  Breach of Contract & UCC Disputes  Medical Malpractice  Business Litigation  Toxic Tort  Chemical-Related Cancers & Diseases

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REPRESENTATIVE CASES

Adelman v. Rheem Manufacturing Company (D. Ariz.): Co-lead counsel in product defect class action.

Ajose v. Interline Brands, Inc. (M.D. Tenn.): Counsel in product defect class action.

Anderson v. Ford Motor Company (W.D. Missouri): Co-lead counsel in vehicle safety defect class action.

Berman v. General Motors (S.D. Fla.): Co-lead counsel in vehicle defect class action.

Chapman v. TriStar Products, Inc. (N.D. Ohio): Lead counsel in multistate defective product class action.

Chason v. Capital City Bank (Gadsden Cty. Cir. Ct., Fla.): Co-lead counsel in overdraft fee class action.

Clark v. Lumber Liquidators (N.D. Ga.): Co-lead counsel in product defect class action.

Curtis v. Alcoa (E.D. Tenn.): Co-lead counsel in ERISA class action.

Davis v. Westgate Planet Hollywood Las Vegas (D. Nev.): Co-lead counsel in a Fair Labor Standards Act case.

Dickerson v. York International Corporation (M.D. Penn.): Co-lead counsel in product defect class action.

Feuquay v. Teachers Credit Union (St. Joseph Cty., Cir. Ct., Ind.): Co-lead counsel in overdraft fee class action.

Floyd v. American Honda Motor Co., Inc. (C.D. Cal., 9th Circuit Court of Appeals): Co-lead counsel in vehicle safety defect class action.

Fultineer v. Lumber Liquidators (W.D. Ky.): Co-lead counsel in product defect class action.

Glenn v. Hyundai Motors America (C.D. Cal.): Co-lead counsel in vehicle safety defect class action.

Harding v. Midsouth Bank (W.D. La.): Co-lead counsel in overdraft fee class action.

Hardwick v. Fluidmaster, Inc. (D.N.H.): Co-lead counsel in product defect class action.

Hatmaker v. Consolidated Nuclear Security, LLC (E.D. Tenn.): Lead counsel in ERISA class action.

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Hindsman v. General Motors (N.D. Cal.): Co-lead counsel in vehicle defect class action.

Hirst v. Skywest Airlines, Inc. (N.D. Ill., 7th Circuit Court of Appeals): Co-lead counsel in employee wage and hour class action.

Hungerman v. Fluidmaster, Inc. (W.D. Penn.): Co-lead counsel in multistate product defect class action.

Hurd v. America’s Collectibles Network, Inc. (Knox Cty. Cir. Ct., Tenn.): Co-lead counsel in consumer protection and false advertising class action.

Jammal v. American Family Insurance Company (N.D. Ohio): Co-lead counsel in ERISA class action.

Jenkins v. Lawrence E. Keeble, Marcelo Pinto and Star Transportation, Inc. (Davidson Cty. Cir. Ct., Tenn.): Lead counsel in personal injury action which led to the single largest auto negligence verdict in Tennessee for 2009.

Johnson v. Direct Shopping Network, Inc. (L.A. Sup. Ct., Cal.): Co-lead counsel in consumer protection and false advertising class action.

Johnson v. Nissan North America, Inc. (N.D. Cal.): Co-lead counsel in vehicle safety defect class action.

Klug v. Watts Regulator Co. (D. Neb.): Co-lead counsel in product defect class action.

Kondash v. Kia Motors America (S.D. Ohio): Co-lead counsel in vehicle safety class action.

Krause v. MB Financial Bank (Cook Cty. Cir. Ct., Ill.): Co-lead counsel in overdraft fee class action.

Lewis v. Allegheny Ludlum Corp. (W.D. Penn.): Co-lead counsel in ERISA class action.

Lowther v. AK Steel (S.D. Ohio): Co-lead counsel in ERISA class action.

Meadow v. NIBCO, Inc. (M.D. Tenn.): Counsel in product defect class action.

Meek v. Skywest Airlines, Inc. (N.D. Cal.): Co-lead counsel in employee wage and hour class action.

Merkner v. AK Steel (S.D. Ohio): Co-lead counsel in ERISA class action.

Michelhaugh v. Consolidated Nuclear Security, LLC (Anderson County Tenn. Cir. Ct.): Lead counsel in breach of contract class action.

Moreno v. Toyota Motor Sales (C.D. Cal.): Co-lead counsel in vehicle safety defect class action.

Mull v. Glacier Bank (Lincoln Cty. Cir. Ct., Mont.): Co-lead counsel in overdraft fee class action.

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Muzingo v. Bank of the Ozarks (Pulaski Cty. Cir. Ct., Ark.): Co-lead counsel in overdraft fee class action.

O’Keefe v. Pick Five Imports, Inc. (M.D. Fla.): Co-Lead counsel in defective product class action.

Price v. L’Oreal USA Inc. (S.D. N.Y.): Co-lead counsel in false advertising class action.

Roberts v. Electrolux Home Products, Inc. (C.D. Cal.): Co-lead counsel in multistate safety defect class action.

Rysewyk v. Sears Holding Corporation (N.D. Ill.): Co-lead counsel in product defect class action.

Samuel v. Chrysler Group LLC (C.D. Cal.): Co-lead counsel in multistate vehicle safety defect class action.

Sanborn v. Nissan North America, Inc. (S.D. Fla.): Co-lead counsel in vehicle safety defect class action.

Sanchez v. General Motors (N.D. Ill.): Co-lead counsel in vehicle defect class action.

Satterfield v. Alcoa, Inc., 266 S.W. 3d 347 (Tenn. 2008): Co-lead counsel in Tennessee Supreme Court case in which the Supreme Court ruled that a duty is owed by Alcoa to a nonemployee household member as it relates to the household member’s contraction of mesothelioma.

Stedman v. Mazda Motor Corp. (C.D. Cal.): Co-lead counsel in multistate vehicle safety defect class action.

Swift v. QNB Bank (Bucks Cty Cir. Ct., Penn.): Co-lead counsel in overdraft fee class action.

Tanasi v. New Alliance Bank (W.D.N.Y.): Co-lead counsel in overdraft fee class action.

Tapp v. Skywest Airlines, Inc. (N.D. Ill.): Co-lead counsel in employee wage and hour class action.

Vickery v. Lumber Liquidators (E.D. Tenn.): Co-lead counsel in product defect class action.

Watson v. Westgate Resorts, Inc. (E.D. Tenn.): Co-lead counsel in a Fair Labor Standards Act case.

West v. East Tennessee Pioneer Oil Co. (Tenn.): A Tennessee Supreme Court case in which the Court ruled a convenience store had a legal duty to the plaintiffs for selling gas to an obviously intoxicated driver.

White v. Nutribullet, LLC (C.D. Cal.): Lead counsel in product defect class action.

Williams v. FCA US LLC (W.D. Missouri): Co-lead counsel in vehicle safety defect class action.

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Gregory F. Coleman | Founder and Managing Partner

Greg Coleman is the Founder and Managing Partner of Greg Coleman Law PC with 30 years of trial and appellate experience. Greg received his B.A. with highest honors and distinction from Jacksonville State University in 1986. He attended The University of Tennessee College of Law, graduating in 1989. In addition to distinguishing himself academically, Greg was a member of the National Trial Moot Court Team, was the recipient of the American Jurisprudence Award for National Trial Team and was listed in Who's Who Among Rising Young Americans. In addition, the College of Law bestowed upon Greg the honor of inclusion into the National Order of Barristers for outstanding oral advocacy and trial skills.

Greg's practice focuses on class actions, products liability, medical malpractice, personal injury, complex multi-district litigation, toxic torts, premises liability, ERISA, ERISA class actions, drug and medical device litigation, and workers' compensation.

He was co-lead counsel in a defective products case against Electrolux in which he and co-counsel successfully obtained a settlement on behalf of a class of more than one million members regarding defectively manufactured dryers. The settlement resulted in an expected utilization settlement value of over $35 million.

Greg was co-lead counsel in a series of automobile defect class actions against General Motors in Florida, Illinois, and California, in which he and co-counsel successfully obtained a $42 million settlement on behalf of a class of 1.6 million consumers regarding excessive oil consumption.

He was lead trial counsel in an ERISA class action against AK Steel Corporation in which he successfully obtained a $178.6 million settlement on behalf of a class of over 3,000 retirees of AK Steel’s Butler Works Plant in Pennsylvania in 2011. Excerpts from the final approval hearing before Judge Black:

“[T]he class has been enormously well represented by the attorneys in this case. I started with the observation that this was a historic moment. I genuinely believe that.

“The plaintiffs and the members of the class have been enormously well represented by counsel.”

“[T]here is no doubt that the settlements herein represent excellent result for the class members and obviate all risk of continued litigation.”

“[T]he Court finds that the hourly and salaried settlements represent excellent result for the class members and provides them with a substantial benefit.”

“I reach the conclusion based on acknowledging the extraordinary benefit achieved for the class, the high level of value of these plaintiffs’ counsel’s services. The lawyers here are excellent, highly regarded, and their service has brought great value to the class.“

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“I acknowledge this was a complex and demanding case involving a great deal of work and that the end result occurred largely, if not fully, attributable to the diligence, determination, hard work of plaintiffs’ counsel, who were vigorously contested, as the company was represented by extraordinary lawyers.

Judge Timothy S. Black, U.S.D.C. S.D. Ohio.

Greg was also lead trial counsel in an ERISA class action case against AK Steel Corporation in which he successfully obtained a $15.8 million settlement on behalf of a class of over 250 retirees of AK Steel’s Zanesville Works Plant in Ohio in 2012.

He was lead counsel in a week-long trucking accident trial in which he obtained the largest negligence verdict in the state of Tennessee for 2009. Jenkins v. Keeble, Davidson County.

Greg Coleman has been and is currently involved in complex product liability and drug product liability litigation and has tried more than one hundred jury trials and countless other bench trials during his career. He has tried jury trials throughout the country and has been admitted pro hac vice in complex matters nationwide, including a six- week long jury trial in Sacramento, California, for which he was lead counsel.

Greg is admitted to practice in the following courts:

 State Courts of Tennessee  United States District Court, Eastern District of Missouri  Tennessee Supreme Court  United States District Court, District of Nebraska  United States Supreme Court  United States District Court, Western District of New York  United States District Court, Eastern District of Tennessee  United States District Court, Eastern District of Wisconsin  United States District Court, Middle District of Tennessee  United States Court of Appeals for the Second Circuit  United States District Court, Western District of Tennessee  United States Court of Appeals for the Third Circuit  United States District Court, District of Colorado  United States Court of Appeals for the Fourth Circuit  United States District Court, Central District of Illinois  United States Court of Appeals for the Fifth Circuit  United States District Court, Northern District of Illinois  United States Court of Appeals for the Sixth Circuit  United States District Court, Southern District of Illinois  United States Court of Appeals for the Seventh Circuit  United States District Court, Southern District of Indiana  United States Court of Appeals for the Ninth Circuit  United States District Court, Eastern District of Michigan  United States Court of Federal Claims

He is certified as a Civil Trial Advocacy Specialist and as a Civil Pretrial Advocacy Specialist by the National Board of Trial Advocacy. Greg is a member of the American Bar Association, Tennessee Bar Association, and is also a member of the Knoxville Bar Association.

Greg is listed in Best Lawyers in America in two separate categories and has been named one of the Top 100 Trial Lawyers by the American Trial Lawyers Association. He was named as Best Lawyers of America Lawyer of the Year in Products Liability and was also named by the U.S. News and World Report as one of the best lawyers and law firms in the country. Additionally, Greg has been recognized as one of Knoxville’s Top Attorneys in eight separate categories. Greg Coleman Law is and has been ranked among the “Best Law Firms” by U.S. News & World Report and Best Lawyer. Greg Coleman Law also received the 2014 and 2015 Litigator Awards from the Trial Lawyers Board of Regents.

Greg is proud to have been recognized by his colleagues through nomination to the Martindale-Hubbell Bar Register of Preeminent Lawyers which includes only those select law practices that have earned the highest rating in the Martindale-Hubbell Law Directory and have been designated by their colleagues as preeminent in their field. He is AV rated by the Martindale Hubble Legal Rating System Judicial Edition and Peer Review Edition, and is a Charter

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Member and Senior Fellow of the Litigation Counsel of America, "a trial lawyer honorary society established to reflect the new face of the American Bar with limited membership representing less than one-half of one percent of American lawyers and is by invitation only." He is a Mid-South Super Lawyer representing the top five percent of Arkansas, Mississippi, and Tennessee attorneys. Greg is a lifetime member of the prestigious Multi-Million Dollar Advocates Forum, an organization whose members are limited to attorneys who have won multi-million dollar verdicts and settlements. He is a Charter member of the Knoxville Chapter of the American Inns of Court and a member of the American Association for Justice and Public Justice. Greg has been featured in Newsweek Magazine in their Showcase of Nationwide Top Attorneys.

Greg has served as a guest lecturer and speaker on Advanced Trial Advocacy and at national seminars, including those sponsored by the Tennessee Bar Association, the National Business Institute, and Mass Torts Made Perfect. He has lectured extensively for many years on topics such as advanced trial tactics and strategy and complex litigation matters. He has authored published materials regarding advanced trial strategy, ethics seminars, as well as numerous other publications for CLE seminars at which he has lectured.

Greg has been actively involved in civil and charitable activities, having served for many years on the Executive Board of Trustees for the Baptist Health System, including the Baptist Hospital of East Tennessee and related entities, and has been involved in many legal aid and pro bono projects in the Knoxville area. Greg and his firm are donors to the annual Mission of Hope Christmas Barrel drive providing warm coats for the children of rural Appalachia. In support of the Knoxville Academy of Medicine and Knoxville Academy of Medicine Alliance’s Conversation Ready Project, Greg performed at the “A Little More Conversation” event. The Conversation Ready Project is a program of the Knoxville Academy of Medicine Foundation and was formed to ensure that everyone’s end-of-life wishes are expressed and respected.

Reported Cases:

West v. East Tennessee Pioneer Oil Co., 172 S.W. 3d 545 (Tenn. 2005), which is a Tennessee Supreme Court case in which the Supreme Court ruled a convenience store had a legal duty to the plaintiffs Gary West and Michelle Richardson (Greg's clients) for selling gas to an obviously intoxicated driver, who then had an accident with Gary West and Michelle Richardson on the roadway. This case was the first case to find that a convenience store had a legal duty to a driver on the roadway (Gary West and Michelle Richardson) for selling gas to an obviously intoxicated driver who then had an accident with Greg's clients.

Satterfield v. Alcoa, Inc., 266 S.W. 3d 347 (Tenn. 2008), which is a Tennessee Supreme Court case in which the Supreme Court ruled that a duty is owed by Alcoa to a nonemployee household member as it relates to the household members contraction of mesothelioma.

Merkner v. AK Steel, 2010 U.S. Dist. LEXIS 12742, 48 BNA 1923.

Lowther v. AK Steel, 2012 U.S. Dist. LEXIS 181476, 54 BNA 1931.

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 Lisa A. White | Senior Attorney

Lisa White is a Senior Attorney at Greg Coleman Law PC working in the areas of complex litigation, class action cases, and wage and hour class and collective actions. She joined the firm in 2014. Her primary areas of focus are product defect class actions (representing consumers who have purchased defective products manufactured by corporations that refuse to “do the right thing” by recalling or repairing the defect, or reimbursing consumers for damages caused by the defect), and fair wage cases (representing current and former employees against businesses that routinely violate the Fair Labor Standards Act and state wage laws). She has taken a lead role in a number of wage-related class actions in the airline industry, which are especially complicated by the intersection of interstate travel, airline regulations, the Railway Labor Act, and the dormant Commerce Clause. She has a lead role in the firm’s ongoing case against SkyWest Airlines, in which the Seventh Circuit Court of Appeals reversed the District Court’s dismissal of claims made on behalf of flight attendants alleging they were underpaid.

 The majority of the cases Lisa works on are filed in the federal court system, both in the District Courts and Circuit Courts of Appeals. Prior to joining Greg Coleman Law, her law practice included extensive trial and appellate experience.

 A writer and researcher at heart, Lisa returned to law school after completing her Bachelor’s in Sociology and Masters in Sociology from The University of Tennessee, and received a Chancellor’s honor for Extraordinary Professional Promise upon graduating. She taught for a number of years at several universities. In addition, she completed the coursework for her PhD in American Studies at The College of William and Mary just prior to entering law school. Lisa is a graduate of The University of Tennessee College of Law.

 While at The University of Tennessee College of Law, Lisa was a Co-Coordinator of Tennessee Innocence Project, the Research Editor for Tennessee Journal of Law and Policy, and practiced in both the Domestic Violence Clinic and the Advocacy Clinic. As a student, Lisa won first place in the American Bar Association's Commission on Domestic and Sexual Violence Student Writing Competition for her paper: “Unlikely Bedfellows: The Intersection Between The Defense of Marriage Act(s) and Domestic Violence Prosecution.”

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Lisa has had a number of papers published in peer-reviewed journals in law as well as in other academic fields including both sociology and history. In Spring 2018, an article she wrote on South Dakota v. Wayfair, Inc., a case that was pending before the U.S. Supreme Court at the time, was published in Dicta, a publication of the Knoxville Bar Association.

 Ms. White has been selected by fellow members of the Knoxville Bar as a "Top Attorney" in CITYVIEW Magazine's annual Top Attorneys’ issue.

 Lisa and her family are avid travelers and she has visited all seven continents. In addition, she has worked remotely for Greg Coleman Law PC while living on the South Island of New Zealand.

 Practice Areas: Class Actions, Fair Labor Practices (including litigation in the airline industry), Consumer Protection/Consumer Rights, Multi District Litigation, Business Litigation, Product Liability, ERISA

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

 Arthur Stock | Senior Attorney

 Arthur Stock joined Greg Coleman Law as a Senior Attorney in 2019. Previously, he had been a shareholder at Berger Montague in Philadelphia, Pennsylvania for over 20 years. Throughout his career, he has represented plaintiffs in commercial, financial, securities, and consumer class actions. He has also represented whistleblowers in qui tam actions in federal courts, and in administrative proceedings before the U.S. Securities and Exchange Commission, the Internal Revenue Service, and the United States Tax Court.

 Mr. Stock was a principal litigator in numerous class actions, including: Merrill Lynch Inc. Securities Litigation, which resulted in a $475 million settlement on behalf of investors in Merrill Lynch securities; Lee v. Enterprise Leasing Co., in which class members recovered 80% of alleged damages from allegedly illegal charges regarding Nevada airport car rentals; and Vasco v. PHRG, an action brought under the Telephone Consumer Protection Act, in which class members recovered $5.2 million from a business that allegedly placed telemarketing calls to consumers without prior express consent.

 Before entering private practice, Mr. Stock served as a Law Clerk to the Honorable Jackson L. Kiser, United States District Court of the Western District of Virginia.

 Representative reported decisions:

 Richardson v. Verde Energy USA, Inc., 354 F.Supp.3d 639 (E.D. Pa. 2018), and 2016 WL 7380708 (E.D. Pa. Dec. 19, 2016), (sustaining complaint and partially denying summary judgment in TCPA class action).

 South Peninsula Hospital v. Xerox State Healthcare LLC, 223 F.Supp.3d 929 (D. Alaska 2016) (sustaining complaint in class action brought on behalf of healthcare providers in Alaska for improper delays and denials of Medicaid reimbursement caused by allegedly defective software).

 Vasco v. PHRG, 2016 WL 5930876 (E.D. Pa. Oct. 12, 2016) (approving consumer class settlement).

 Lee v. Enterprise Leasing Co.-West, 2015 WL 2345540 (D. Nev. May 15, 2015), and 300

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F.R.D. 466 (D. Nev. 2014), and 30 F.Supp.3d 1002 (D. Nev. 2014) (granting plaintiffs’ motions for summary judgment, class certification, and approval of settlement, in consumer class action alleging overcharges on airport car rentals).

 In re Clarus Corp. Securities Litigation, 201 F.Supp.2d 1244 (N.D. Ga. 2002) (sustaining complaint in securities fraud class action).  Publications:

 “Theory v. Practice: A Comment on Orin Kerr’s ‘A Theory of Law’,” 16 Green Bag 2d 224 (Winter, 2013)

 “Make Way for Lawsuits,” 11th Annual NERA Finance, Law & Economics Securities Litigation Conference

 Education:

 Yale University, B.A. with distinction in economics o Two majors: economics and philosophy

 Duke University School of Law, J.D. with high honors o Articles Editor, Duke Law Journal o Order of the Coif

Admissions:

State Courts of Pennsylvania State Courts of North Carolina Pennsylvania Supreme Court United States District Court of the Eastern District of Pennsylvania United States Court of Appeals for the Seventh Circuit United States Court of Appeals for the Ninth Circuit United States Tax Court

Practice Areas: Class Actions, Complex Litigation, Fair Labor Practices, Consumer Protection, Consumer Rights

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Ryan P. McMillan | Associate

Ryan is a native of East Tennessee and grew up in Oak Ridge. There he was active in the Boy Scouts and competitive rowing. He attended the University of Mary Washington in Fredericksburg, Virginia, where he received his Bachelor’s Degree, cum laude, in History.

Ryan returned to Tennessee in 2006 and later went to law school at the University of Tennessee, where he focused primarily on employment law. While in law school he clerked for the United States Department of Energy and London and Amburn, P.C. He also was a staff editor for the Tennessee Journal of Law and Policy and received the Patrick L. Hardin Award for Excellence in Employment and Labor Law.

After law school, Ryan worked at Dale Buchanan and Associates for many years where he represented thousands of disabled clients.

In 2019, Ryan joined Greg Coleman Law to continue his work in representing plaintiffs, primarily in class action and complex litigation matters.

Ryan lives in Alcoa with his wife and son. In his free time, Ryan enjoys hiking in the Smokies, spending time with his family, and traveling.

Practice Areas: Class Actions, Complex Litigation, ERISA, Disability Law

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Jeffrey Glaspie| Former Associate

Jeff is a native of East Tennessee growing up in Sevier County. He graduated from East Tennessee State University with a Bachelor’s Degree in sociology and political science. While at ETSU, Jeff was active in student government and the campus community. Following graduation, he joined the Tennessee Air National Guard where he served as a telecommunication technician and Law Office Superintendent.

Jeff attended law school at Duncan School of Law in Knoxville, Tennessee where he graduated magna cum laude. While there, he served as a senator on the Student Bar Association, Executive Articles/Notes Editor of the LMU Law Review, was the recipient of the 2012 Donald F. Payne Scholarship and clerked with Chief Justice Gary R. Wade on the Tennessee Supreme Court.

Jeff practiced at Greg Coleman Law in 2018 and 2019, primarily in the areas of complex litigation and class action cases. Jeff is admitted to practice in Tennessee state courts and the United States District Court for the Eastern District of Tennessee.

Practice Areas: Class Actions, Consumer Protection, Mass Torts, and Personal Injury

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Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Greg Coleman P.C. Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Coleman, Gregory P 3.50 $725.00 $2,537.50 Stock, Arthur A 76.10 $625.00 $47,562.50 Stock, Arthur (document review) A 397.10 $300.00 $119,130.00 White, Lisa A 0.70 $625.00 $437.50 Ladnier, Will A 0.40 $425.00 $170.00 Glaspie, Jeffrey A 29.70 $425.00 $12,622.50 McMillan, Ryan A 20.60 $425.00 $8,755.00 Maxwell, Lisa PL 30.80 $200.00 $6,160.00 Hold, Dawn PL 1.00 $250.00 $250.00 TOTALS 559.9 $197,625.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 66 of 253 PageID# 11489

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Greg Coleman P.C. Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees $75.00 Overnight Delivery/Messengers Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $2,123.54 Litigation Fund Contributions $50,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $52,198.54 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 67 of 253 PageID# 11490

Exhibit A-16 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 68 of 253 PageID# 11491

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF JASON HARTLEY IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Jason Hartley hereby declare as follows:

1. I am a partner at the law firm of Hartley LLP. I submit this declaration in support

of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement of

Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Hartley LLP and its attorneys are

summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 710.3. The total lodestar for my firm is $250,436.50. My firm’s lodestar amount

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 69 of 253 PageID# 11492

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm’s attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm’s contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm’s lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $41,263.71 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $40,000 in

contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 70 of 253 PageID# 11493

Executed this 26th day of April, 2021 at San Diego, California.

s/ Jason S. Hartley Jason S. Hartley

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Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 72 of 253 PageID# 11495

Ill HAATLEYLLP

101 West Broadway, Suite 820 San Diego, California 92101 (619) 400-5822 http://hartleyllp.com Email: [email protected]

Firm Profile:

Hartley LLP was formed in 2018, from founding partners who had previously worked together for nearly two decades. Hartley LLP attorneys have extensive experience in all aspects of complex plaintiffs’ contingency litigation, including antitrust, consumer protection, unfair competition, wage and hour, and other large class action cases.

Hartley LLP lawyers have served as Court-appointed Lead or Co-Lead Class Counsel in multiple coordinated multi-district litigation actions, as well as numerous Executive Committee and other leadership positions in all forms of complex litigation.

Judges in class action cases have stated that Hartley LLP lawyers “ably represented their clients and vigorously pursued their case” and noted Hartley LLP’s experience in antitrust and class action litigation, including the ability to navigate difficult litigation hurdles such as overseas depositions while achieving settlements with multiple defendants for class members.

Clients have stated that they have “never had more competent counsel,” that Hartley LLP lawyers were “knowledgeable and helped make our case with minimal impact to the business” while being “fun to work with,” and that founding partner Jason Hartley is a “fierce negotiator.”

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Attorneys

Jason S. Hartley Founding Partner

Jason exclusively represents plaintiffs in commercial contingency representation, class action litigation, antitrust, and unfair competition. He is involved in all aspects of civil litigation and has handled cases in both federal and state courts, in litigation and at trial. For the past several years, his practice has involved primarily antitrust and consumer class actions, often representing the largest plaintiff class members in nationwide antitrust actions.

Jason has successfully represented plaintiffs in federal Section 1 (conspiracy) and Section 2 (monopoly) Sherman Act cases and in state law actions alleging unfair business practices, false advertising, pharmaceutical “sham patent” and “pay-for-delay “cases, among other claims. He has developed an expertise litigating against foreign defendants, most notably in Asia. Jason has represented a number of Fortune 500 companies as plaintiffs and served as lead counsel and in senior litigation roles in numerous class actions, which have collectively recovered billions of dollars for plaintiffs.

Jason has obtained notable results for his clients in numerous groundbreaking decisions and on issues of first impression. For example, he obtained the first ever certification of a class of purchasers in a patent related Walker Process antitrust claim (Alfred T. Giuliano, et al. v. SanDisk Corporation, Case No. 4:10-cv-02787, ECF 302 (N.D. Ca. 2015)); he obtained the first and only court-ordered denial of ACPERA protection claimed by Defendants cooperating with the Department of Justice, thus increasing three-fold the potential damages available to the plaintiffs he represented (In re Aftermarket Automotive Lighting Products Antitrust Litigation, 2013 WL 4536569 (C.D.Ca. 2013)) and he obtained the denial of a motion to dismiss based upon the Foreign Trade Antitrust Improvements Act (“FTAIA”) in a case that helped set the standard for FTAIA dismissal motions (Fond du Lac Bumper Exchange, Inc. v. Jui Li Enterprise Co. Ltd., et al; 753 F. Supp.2d 792 (E.D.Wis. 2010)).

Jason has been appointed by federal courts around the country as plaintiffs’ class counsel in over a dozen cases, which have recovered hundreds of millions of dollars for his clients. He was chosen by the Judges of the Southern District of California to serve as a lawyer representative since 2017, is part of the planning committee for the ABA’s Institute on Class Actions, and regularly speaks at CLE seminars and publishes articles on class and antitrust issues. He was recognized as “Best of the Bar” by the San Diego Business Journal in 2017, a “Man of Influence” by San Diego Metro magazine in 2019 and a 2020 Top Antitrust Attorney by California’s Daily Journal. He serves on the Board of both the American Association for Justice and the Consumer Attorneys of California, has an AV rating and has been selected by his peers as a Super Lawyer for the last eight consecutive years.

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Education

• Tulane Law School, J.D. cum laude 1997 Honors: Winner, Nathan Burkan Memorial Writing Competition by ASCAP Law Journal: Tulane Journal of International and Comparative Law, Assistant Executive Editor • University of California, San Diego, B.A. 1993 • Honors: Provost’s Honor List

Community Involvement

• San Diego Museum of Man, Balboa Park (Board of Trustees) • San Diego Regional Economic Development Corporation (Policy Committee) • ElderHelp of San Diego (Fundraising Committee Member) • YMCA Adventure Guides (Circle Chief)

Professional Organizations

• American Bar Association (Member) • American Association for Justice (Board of Governors) • Consumer Attorneys of California (Board of Directors, Board of Governors) • Consumer Attorneys of San Diego (Member) • San Diego County Bar Association (Member) • American Bar Foundation (Fellow) • The National Trial Lawyers, Top 100 (Member)

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Jason M. Lindner Partner

Jason’s practice includes litigation of antitrust, unfair competition, complex business, California wage and hour, Fair Labor Standards Act, and other general class action litigation. He has been involved in all aspects of civil litigation in both federal and state courts.

Jason has successfully represented plaintiffs in federal Section 1 and Section 2 Sherman Act cases and in state law actions alleging unfair business practices. He has also represented classes of plaintiff employees under both the FLSA and under California State wage and hour statutes. He has served as lead counsel and in senior litigation roles in numerous class actions, which have collectively recovered billions of dollars for plaintiffs.

Education

• University of Miami, B.A., cum laude, 1997 • University of Pennsylvania, J.D., 2000

Community Involvement & Publications

• Super Lawyers – San Diego 2015-2018 • Twice received the Wiley M. Manuel award for excellence in providing Pro Bono Legal Services • “Class Action Litigation in the United States and Mexico” – San Diego Bar Panelist and Author (October 2012) • “How Does a Participant Withdraw From a Conspiracy?” Section of the American Bar Association Section of Antitrust Law’s Proof of Conspiracy Under the Federal Antitrust Law • “Background of the Illinois Brick Decision,” Appendix, American Bar Association Section of Antitrust Law’s Indirect Purchaser Litigation Handbook • Co-Author, “Monopolization in Telecommunication Markets,” Chapter of American Bar Association Section of Antitrust Law’s Telecommunications and Antitrust Practice Guide

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Dylan J. McFarland Of Counsel

Dylan brings a wealth of knowledge and experience to the practice of complex commercial civil litigation. Most recently he worked at Heins Mills & Olson, PLC, first as a partner and then as of counsel, where he represented plaintiff classes comprising individuals, governmental entities, and closely and publicly held corporations asserting violations of antitrust, securities fraud, unfair competition, and consumer protection laws. During his career, Dylan has first-chaired more than two dozen trials, and has briefed and argued numerous appeals in both federal and state courts.

Dylan has participated in some of the nation’s largest and most challenging cases. In the arena of securities fraud, for example, he was the principal brief writer for the plaintiff shareholder class in In re AOL Time Warner Securities Litig. (S.D.N.Y.), which achieved a $2.65 billion recovery for shareholders who allegedly suffered losses as a result of the merger of AOL and Time Warner. He played a similar role in In re Broadcom Corp. Securities Litig. (C.D. Cal.), which recovered $150 million for shareholders of a semiconductor manufacturer.

Dylan has also been involved in a number of antitrust class actions that have resulted in large recoveries. Examples include In re Municipal Derivatives Antitrust Litig. (S.D.N.Y.) (alleging bid-rigging of municipal derivatives by brokers and financial institutions); In re TFT-LCD (Flat Panel) Antitrust Litig. (N.D. Cal.) (alleged price-fixing by producers of LCD screens); In re LIBOR-Based Financial Instruments Antitrust Litig. (S.D.N.Y.) (alleging conspiracy by British Bankers’ Association member banks to manipulate London InterBank Offered Rates); In re Payment Card Interchange Fee and Merchant Discount Antitrust Litig. (E.D.N.Y.) (representing opt-out merchants alleging conspiracy by Visa, Mastercard and their network banks to charge excessive fees for accepting their brand credit and debit cards); In re Lidoderm Antitrust Litig. (N.D. Cal.) (alleging anticompetitive conduct by pharmaceutical companies to delay generic competition with Lidoderm transdermal patches); In re Foreign Exchange Benchmark Rates Antitrust Litig. (S.D.N.Y.) (alleging conspiracy by international financial institutions to manipulate foreign exchange currency rates).

Dylan also worked on class actions arising in other areas of law, including In re National Hockey League Players’ Concussion Injury Litig. (D. Minn.) (alleging negligence claims against the NHL on behalf of retired NHL hockey players for concussion-related brain injuries); In Re Target Corporation Customer Data Security Breach Litigation (D. Minn.) (seeking damages for Target customers caused by one of the largest payment card security breaches in U.S. history); Simmons v. Kemp (D. Minn.) (recovering a $100 million payment from HUD on behalf of the Minneapolis Public Housing Authority and Minneapolis Community Development Agency as part of a consent decree to remedy unlawful racial segregation in the original siting of public housing in Minneapolis).

In addition to his private practice, Dylan was an adjunct Professor of Law from 1997 to 2002 at the Mitchell Hamline School of Law in St. Paul, Minnesota, which has one of the top-

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rated clinical programs in the country. In that program he taught law students trial skills, appellate advocacy and legal writing.

Education

Harvard Law School J.D. cum laude

• Note and Comment Editor, Harvard Civil Rights–Civil Liberties Law Review • Legal Writing teaching assistant • Harvard University varsity men’s track & field and cross–country (one year)

University of Minnesota Medical School No degree

University of Minnesota B.A. summa cum laude

• Phi Beta Kappa • Varsity men’s track & field and cross–country

Community Involvement & Publications

• Former “Super Lawyer,” Minnesota Law & Politics • Former “Rising Star,” Minnesota Law & Politics • “Litigation Star,” Benchmark Plaintiff: The Definitive Guide to America’s Leading Plaintiff Firms & Attorneys

6 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 78 of 253 PageID# 11501

Fatima Brizuela Associate

Fatima’s practice includes antitrust, unfair competition, and consumer protection litigation with a focus on complex class action matters involving price-fixing, illegal tying, and unlawful monopolization. Fatima has represented classes of individuals and businesses harmed by anticompetitive conduct from initial pre-suit evaluation of claims all the way through to class certification and final approval of final settlements. Fatima’s recent work includes representation of a class of participants who traded futures and options in the foreign exchange market, alleging that defendant banks colluded to manipulate foreign exchange rates, in In re Foreign Exchange Benchmark Rates Antitrust Litigation (S.D.N.Y.); In re Cathode Ray Tube Antitrust Litigation (N.D. Cal.) (representing an end-user class of businesses and consumers alleging that manufacturers of cathode ray tubes conspired to fix, raise, maintain, and/or stabilize prices, thereby harming end-users who paid artificially inflated prices for CRT products); In re Disposable Contact Lens Antitrust Litigation (M.D. Fla.) (representing a class of consumers alleging that manufacturers of disposable contact lenses engaged in a “hub and spoke” conspiracy to coordinate prices through what defendants characterized as “unilateral pricing policies”).

Education

California Western School of Law, J.D. 2015 Honors: Wiley M. Manuel award recipient providing Pro Bono Legal Services Associate Writer, California Western International Law Journal AMJUR – Antitrust Law

Rutgers University, B.A. 2009 Honors: Summa Cum Laude Phi Beta Kappa Pi Sigma Alpha

7 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 79 of 253 PageID# 11502

Teresa Jones Attorney

Teresa’s practice includes antitrust, unfair competition, and consumer protection litigation with a focus on complex class action matters.

Most recently she worked at Heins Mills & Olson, PLC, where she represented plaintiff classes asserting violations of antitrust, securities fraud, unfair competition, and consumer protection laws.

During her career, Teresa represented plaintiffs in a number of antitrust class actions alleging anticompetitive conduct by pharmaceutical companies to delay entry of lower priced generic drugs into the market, including In re Lidoderm Antitrust Litigation, MDL No. 2521 (N.D. Cal.)(resulting in the September 2018 final approval of a $104.75 million settlement, a week before jury selection, representing one of the largest recoveries by end-payors in a federal “pay- for-delay” generic suppression case in more than a decade); In re Aggrenox Antitrust Litigation, MDL No. 2516 (D. Conn.) (resulting in July 2018 final approval of a $54 million settlement for the end-payor plaintiffs), and In re Lipitor Antitrust Litigation MDL No. 2332 (D.N.J.) (antitrust claims for alleged patent fraud, sham litigation and an anti-competitive reverse payment scheme on behalf of proposed class of indirect purchasers).

She is currently working on In re Generic Pharmaceuticals Pricing Antitrust Litigation, MDL 2724 (ED Pa) (a massive nationwide case alleging that dozens of the world’s largest drug makers conspired to raise prices, allocate the market, and prevent competition on commonly used generic drugs); In re Interior Molded Doors Antitrust Litigation, 3:18-cv-00718-JAG (E.D. Va.)and 3:18-cv-00850-JAG (E.D. Va.) (alleging that the two largest producers of interior molded doors entered into an illegal price fixing agreement to control the market for interior doors); and,In re Diisocyanates Antitrust Litigation, MDL No. 2862 (alleging a conspiracy to fix prices for MDI and TDI products, the precursor ingredients for polyurethane foam).

Teresa’s prior experience includes some of the most notable antitrust cases in the country, such as In re Target Corporation Customer Data Security Breach Litigation (D. Minn.) (representing consumers against Target Corporation arising from one of the largest payment card security breaches in U.S. history); In re Domestic Drywall Antitrust Litigation (E.D. Pa.) (supply and price-fixing claims against manufacturers of gypsum wallboard); Fond Du Lac Bumper Exchange, Inc., et. al. v. Jui Li Enterprise Company, Ltd., et. al. (E.D. Wis.) (supply and price– fixing claims against manufacturers and distributors of aftermarket automotive sheet metal parts); In re Plasma Derivative Protein Therapies Antitrust Litigation (N.D. Ill.) (supply and price-fixing claims against manufacturers of plasma-derivative protein therapies); In rePolyurethane Foam Antitrust litigation, MDL. No. 2196 (N.D. Ohio) (price-fixing claims on behalf of a class of direct purchasers); Glaberson v. Comcast Corp. (E.D. Pa.) (antitrust claims against cable services provider on behalf of subscribers); and In re AOL Time Warner Securities Litigation (S.D.N.Y) (securities fraud claims on behalf of AOL and Time Warner shareholders, achieving a $2.65 billion recovery for the plaintiff shareholder class).

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Prior to Heins Mills and Olson, Teresa was part of the trial team in a large antitrust class action lawsuit against a major software company which settled in 2007 after several months of trial for $180 million.

Teresa graduated magna cum laude from William Mitchell College of Law and is admitted to practice in the state courts of Minnesota, the U.S. District Court for the District of Minnesota, and the United States Court of Appeals for the Eighth Circuit. Teresa has held leadership positions in the Minnesota State Bar Association, Hennepin County Bar Association and American Bar Association.

Education

• William Mitchell College of Law, St. Paul, MN., J.D. 1996 Honors: Magna Cum Laude

• University of Minnesota, Minneapolis, MN., B.A. 1992 Honors: Honors Major: Sociology / Criminology

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Case Results

Hartley LLP attorneys have achieved successful results in all forms of complex class action litigation. Below are a select few examples.

In re: Urethane Antitrust Litig., No. 04-md-01616 (D. Kan.)

Hartley LLP attorneys were appointed Co-Lead Counsel for plaintiffs by the court in this nationwide antitrust MDL case. The complaints asserted a class action on behalf of companies in the United States that purchased the input chemicals to manufacture polyurethane products. Polyurethane is made by the combination of a polyol and an isocyanate. The two major polyols used are polyester polyols and polyether polyols. This first Urethanes class action concerned a conspiracy to fix and raise the prices of polyester polyols manufactured by Crompton/Chemtura, Bayer, Rhein Chemie and Uniroyal Chemical. The case settled for over $33 million.

Aftermarket Automotive Lighting Prods. Antitrust Litig., No. 09-ML-2007 (C.D. Cal.)

Hartley LLP attorneys were the first to file this case behalf of a class of businesses that purchased aftermarket automotive lighting products. Months after the civil antitrust cases were filed, the United States Department of Justice intervened in the case and announced their criminal investigation of Defendants antitrust violations. Hartley LLP attorneys, as court-appointed Lead Counsel, worked in conjunction with the DOJ attorneys to bring the case to a successful resolution. The defendants included Taiwan-based companies and their U.S. subsidiaries that manufactured and sold replacement automotive lighting products such as headlights and taillights to businesses around the country. Hartley LLP attorneys reviewed millions of pages of foreign language documents and took numerous foreign language depositions of defendants. The case settled weeks before trial was scheduled to commence for over $53 million.

Fond du Lac Bumper v. Gordon, et al., No. 09-CV-0852 (E.D. Wis.)

Hartley LLP attorneys spent months investigating this proprietary case before filing it in 2009. Hartley LLP are court-appointed Lead Counsel on behalf of companies in the U.S. that purchased automotive sheet metal parts, such as hoods, fenders, and panels. The case alleges that each of the defendants, all of which are located in Taiwan, conspired to fix the prices of aftermarket sheet metal products sold in the United States. Defendants implemented their conspiracy in several ways, including routine price fixing agreements, client allocation, and joint tooling agreements in which some Defendants mothballed their tools for making certain parts in order to give production control to a single Defendant, eliminating competition for the tool and setting higher prices for customers. Hartley LLP attorneys recovered more than $30 million in settlements for the Class.

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In re Payment Card Interchange Fee and Merchant Discount Antitrust Litigation, No. 05-md- 01720 (E.D.N.Y)

Hartley LLP attorneys are part of the executive committee in this ground-breaking antitrust case, one of the largest in U.S. history. In it, merchants challenged the very structure of the credit card industry, asserting that the setting of interchange fees by credit card associations and banks constitutes illegal price fixing. The case also challenges the credit card associations’ ability to constrain merchant choice by not allowing surcharge fees or minimum purchase amounts for credit card use. The parties reached a settlement that was approved for up to $6.26 billion in cash for merchants across the country. The settlement is currently on appeal.

Spangler, et al., v. National College of Technical Instruction, et al., No. 14-cv-03005-DMS- RBB (S.D. Cal.)

Hartley LLP attorneys were appointed class counsel for a class of students of NCTI, a subsidiary of AMR, one of the country’s largest provider of emergency medical responders. Those students alleged that NCTI failed to timely provide the necessary internships as required under the law, misrepresented the duration of instruction before eligibility for licensing as an EMT, and misrepresented the potential for job placement, among many other violations. Even before trial or settlement of the action, Hartley LLP attorneys obtained summary judgment in favor of class members on misrepresentations that NCTI students would receive preferential treatment when seeking jobs with AMR. The case then settled, providing hundreds of thousands of dollars in restitution to students who were delayed in their internships.

In re: Railway Industry Employee No-Poach Antitrust Litig., No. 18-mc-00798 (W.D. Pa.)

Hartley LLP represented one of the named plaintiffs pursuing antitrust claims on behalf of employees against Wabtec and Knorr-Bremse. These companies agreed not to solicit, hire, or poach each other’s employees in order to keep wages suppressed. These no-poach agreements restricted competition for their workers, which limited workers’ access to better job opportunities, restricted their mobility, and deprived them of significant information that they could have used to negotiate for better terms of employment. The case settled in 2020 for nearly $50 million.

Steve Johnson and Scott Sollitt v. U.S. Bank National Assn., No. 3:19-cv-0286-JLS-LL (S.D. Cal.)

Hartley LLP represented US Bank loan originators. The complaint alleged that US Bank failed to properly compensate its loan originators, including failing to pay commissions for work done if the employee left US Bank before the loan closed. Judge Sammartino of the Southern District of California granted approval of a settlement of $6.5 million in this class action on behalf of California workers.

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Johnson v. Harvest Management Sub Trs Corp., et al., No. 12-cv-00662 (S.D. Cal.)

Hartley LLP attorneys were co-class counsel on behalf of a class of California managers of retirement communities who alleged that they were not properly paid for overnight shift work. These class members worked in difficult conditions, caring for the sick and elderly, and often had to respond to calls all throughout the night when staying at the facilities, but were not paid for that time. Hartley LLP ultimately obtained a $5.5 million dollar settlement for the class.

In re: Bank of America Wage and Hour Employment Practices Litig., No. 10-md-02138 (D. Kan.)

Hartley LLP attorneys litigated this case as court-appointed Co-Lead Counsel on behalf of a class of all retail bank tellers, loan officers, and call center employees against one of the largest banks in the nation. Class members alleged that, although the bank required overtime, it enforced standards that caused class members to work off-the-clock. Class members also alleged that the bank failed to properly provide meal and rest breaks, and that call center employees were not properly compensated for pre- and post-shift work activities. Hartley LLP attorneys ultimately obtained a $73 million dollar settlement for the class members.

Leiszler, et al. v. Align Technologies, No. 10-CV-2010 (N.D. Cal.)

Hartley LLP attorneys were Class Counsel for a class of more than 22,000 dentists against the maker of Invisalign for unfair competition in suspending or decertifying dentists who did not prescribe a minimum number of new Invisalign cases. Align Tech unilaterally imposed new restrictions and quota requirements as prerequisites to maintain dentists’ certification to prescribe Invisalign after the dentists had already spent thousands of dollars and underwent training to obtain certification. Hartley LLP attorneys obtained a settlement that amounted to a 100% recovery for the class, with a value of more than $50 million in cash and non-cash relief.

Alfred T. Giuliano, et al. v. SanDisk Corporation, No. 10-cv-02787 (N.D. Ca.)

Hartley LLP attorneys were co-lead counsel for a class of purchasers of flash memory products from Sandisk in this “Walker Process” antitrust litigation. Plaintiffs alleged that Sandisk fraudulently obtained its “crown jewel” patents regarding flash technology that it then used to exclude competitors and charge monopoly rents on its customer. The Northern District of California certified the class of purchasers in the nation’s first class certification of a Walker Process claim.

Moore v. The Geo Group, Inc., No. 37-2009-0098066 (Cal. Sup. Ct.)

Hartley LLP attorneys were Class Counsel in a case representing a group of officers working at private correctional facilities who were not properly paid overtime due to an automatic rounding of their time entries by the facilities’ computer systems. The class members ultimately received a confidential settlement which was calculated to be well in excess of the actual time they were owed.

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Zeismer v. Linens-N-Things, No. 06-cv-1194 (S.D. Cal.)

Hartley LLP attorneys served as Lead Counsel for this nationwide consumer class action alleging false representation of certain bed sheets. Linens N Things claimed that the thread count of its bed sheets was more than twice what it actually was, according to laboratory tests. The settlement resulted in replacement sheets available to every class member around the country.

In re: Capacitors Antitrust Litigation, No. 14-cv-03264-JD (N.D. Cal.)

Settlements with all but three defendants total more than $400 million. The case continues against the remaining defendants, UCC and NCC.

Childers IV, et al. v. The New York and Presbyterian Hospital, et al., No. 12-cv-05414 (S.D.N.Y)

Hartley LLP attorneys represented thousands of medical students who conducted their residency at New York Presbyterian Hospital (NYP), one of the largest hospitals in the country. The complaints alleged that from 1995 to 2001 NYP took FICA taxes out of the residents’ paychecks, which deductions were improper for students under a retroactive 2010 IRS rule. When NYP residents asked NYP to file refund requests with the IRS, as every other hospital in the country was doing, the residents learned that NYP had negotiated away its right to request a refund or return of the FICA taxes it had taken from residents’ paychecks as part of a settlement NYP made with the IRS in an unrelated dispute. Hartley LLP attorneys negotiated a settlement that got each of the residents a significant portion of their FICA taxes back from NYP.

In Re: Korean Air Lines Co. Ltd. Antitrust Litig., MDL No. 07-01891 (C.D. Cal.)

Hartley LLP attorneys served as plaintiffs’ counsel in this nationwide class action against Korean Airlines and Asiana Airlines. The plaintiffs alleged that the airlines conspired to fix flight surcharges to passengers flying to and from the United States, costing the passengers millions of dollars. Settlements were reached with the defendants, totaling $50 million in cash and $36 million in flight vouchers.

In re: Buspirone Antitrust Litig., MDL No. 1410 (S.D.N.Y)

Hartley LLP lawyers represented plaintiffs in this nationwide class action against the manufacturer of the drug Buspar for artiﬁcially inﬂating prices. The case settled for $535 million.

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In re: Relafen Antitrust Litig., No. 01-12239-WGY (D. Mass.)

Hartley LLP attorneys represented the world’s largest pork producer and only self-insured plaintiff in a nationwide class action against the company manufacturing the drug Relafen for artiﬁcially inﬂating prices. The case settled for $75 million.

In re: Methionine Antitrust Litig. No. 00-1311 (N.D. Cal.)

Hartley LLP attorneys represented the largest plaintiff in a nationwide class action for price ﬁxing an animal feed additive. The case settled for $109 million.

Active Litigation

Hartley LLP is constantly involved in the prosecution of many forms of complex class action litigation. Below are a few examples of our currently active cases:

In re: Diisocyanates Antitrust Litig., No. 2:18-mc-01001-DWA (W.D. Pa.)

Hartley LLP was appointed co-lead counsel in this nationwide antitrust price-fixing action. The complaint alleges that the prices of isocyanates MDI and TDI which, when combined with polyols form a polyurethane, were artificially manipulated by their manufacturers. Bayer, BASF, Covestro, Huntsman, Dow, and Mitsui are alleged to have jointly raised prices and engaged in coordinated efforts to close manufacturing plants that limited production and increased prices. The majority of these defendants were previously subpoenaed by the Department of Justice as part of a government investigation into this industry.

In re: DPP Beef Litigation, No. 20-cv-1319-JRT-HB (D. Minn.)

Hartley LLP was appointed co-lead counsel in this nationwide antitrust price-fixing case. Direct purchasers of beef from defendants Tyson, JBS, National Beef and Cargill claim those suppliers artificially manipulated the price of this $5 billion market. Defendants are accused of throttling the supply of beef, among other things, in order to raise its prices.

Jessica Robinson, et al. v. Jackson Hewitt, Inc., et al., No. 2:19-cv-9066- SDW-ESK (D.N.J.)

Hartley LLP was appointed co-lead counsel in this class action against the tax preparing firm Jackson Hewitt. The complaint alleges an illegal conspiracy among Jackson Hewitt companies not to solicit or poach each other’s employees. The effect of these agreements was to depress employees’ wages, restrict their ability to move jobs, and limited their leverage to negotiate better pay. The damaging effect was emphasized by the fact that these workers had a unique skillset with the Jackson Hewitt model that made defendants natural alternative employers for these workers across more than 6,000 locations. The case is pending in the District of New Jersey

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Persian Gulf, Inc. v. BP West Coast Products LLC, et al., No. 3:14-cv-1749-DMS-AGS (S.D. Cal.)

Hartley LLP represents a California class of direct purchasers of gasoline in this antitrust case against the country’s largest refiners, BP, Exxon, Chevron, Shell, Valero, Tesoro, Phillips66 and others. The complaint alleges that the defendants coordinated plant shutdowns, exported specially formulated CARBOB outside of California and otherwise conspired to manipulate the market to keep the price of California gasoline artificially high.

BLS Pharma, Inc. v. Inovio Pharmaceuticals, Inc. and Genetronics, Inc., No. 30-2019- 01119045 (Orange County Superior Court)

Hartley LLP represents BLS Pharma in a breach of contract and misrepresentation case against Inovio (NASDAQ-INO) and Genetronics. The lawsuit alleges that Inovio refused to honor its obligation to supply needle-free syringes (Zetajets) to BLS, which were needed for its testosterone therapy drug-device combination (DDC). BLS’s DDC, which presented a clear path to FDA approval, was the only one of its kind and would have permitted patients to administer testosterone in their own homes without the expense, discomfort and infection risk of a needle puncturing the skin. Despite receiving a purchase order, issuing an invoice and receiving payment, Inovio flatly refused to supply the syringes and provided no legitimate reason for the breach.

Turlock v. Merck & Co., Inc., No. 18-cv-00352 (E.D. Va.)

Hartley LLP is pursuing claims on behalf of end-payors of the prescription drug ExForge, which is used to treat high blood pressure. The complaint, filed in the Southern District of New York, alleges that Novartis, Par (now part of Endo) conspired to keep a cheaper generic version of ExForge off the market starting in 2012. Novartis’ patent for ExForge expired in 2012, and under the federal Hatch-Waxman Act, Par Pharmaceuticals was poised to introduce a generic version of ExForge in the U.S.. Instead, Par agreed with Novartis to not bring a generic version to market in exchange for over $100 million in cash value from Novartis. The branded drug ExForge sells over $400 million annually in the United States alone, so with generic versions taking 80% or more of a market at an average discount of 50% off the price, buyers of the drug suffered hundreds of millions of dollars in damages, according to the complaint.

In re: Zetia (Ezetimibe) Antitrust Litig., No. 18-md-02836 (E.D. Va.)

Hartley LLP represents the Turlock Irrigation District in this end-payor antitrust action alleging that Merck, Schering-Plough, and Glenmark Pharmaceuticals conspired to keep the generic version of the drug Zetia, used to reduce cholesterol and prevent the buildup of plaque in arteries, off the market and thus keep prices at inflated levels.

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In re: Generic Pharmaceuticals Pricing Antitrust Litigation, No. 16-md-2724-CMR (E.D. Pa.)

Hartley LLP represents a class of end-payors of dozens of generic drugs in this nationwide price fixing case. The lawsuit alleges a conspiracy to fix the prices of generic drugs, resulting in price increases since March 2011. The Antitrust Division of the U.S. Department of Justice continues a wide-ranging parallel criminal investigation of the same conduct.

In re: Packaged Seafood Products Antitrust Litig., No. 15-md-02670 (S.D. Cal.)

Hartley LLP represents named plaintiff Trepco Inc. in this nationwide price-fixing case. The complaint alleges that the country’s largest packaged seafood and canned tuna producers, including Starkist, Chicken of the Sea and Bumble Bee, conspired to artificially raise the prices of packaged seafood products sold in the United States. The case implicates over $10 billion of U.S. commerce, and was the subject of a Department of Justice investigation that has already led to multiple criminal guilty pleas among senior executives of the defendant companies. Hartley LLP continues to prosecute the civil action, seeking damages on behalf of purchasers of packaged seafood that overpaid as a result of the unlawful conspiracy.

In re: Capacitors Antitrust Litigation, No. 14-cv-03264-JD (N.D. Cal.)

Hartley LLP represents U.S. purchasers of aluminum and tantalum electrolytic capacitors and film capacitors. Capacitors are a ubiquitous passive components found in virtually every electronic device. They store an electric charge which allowed devices to remember data even when they are powered down. The complaint alleges that the major manufacturers of capacitors conspired to fix the prices of products sold in the United States. The defendants include including Panasonic Corporation, SANYO Electric Co., Ltd., NEC TOKIN Corporation, KEMET Corporation, Nippon Chemi-Con Corporation, United Chemi-Con, Inc., Fujitsu Ltd., Nichicon Corporation, AVX Corporation, Rubycon Corporation, ELNA Co., Ltd., Matsuo Electric Co., Ltd., TOSHIN KOGYO Co., Ltd., Holy Stone Enterprise Co., Ltd., Vishay Polytech Co., Ltd., ROHM Co., Ltd., Okaya Electric Industries Co., Ltd., Taitsu Corporation, Shinyei Kaisha, Nitsuko Electronics Corporation, Nissei Electric Co., Ltd., Soshin Electric Co., Ltd., and Shizuki Electric Co., Ltd. A criminal investigation by the U.S. Department of Justice into potential antitrust violations in the capacitors industry is ongoing. To date, seven defendants, ELNA, Hitachi, Holy Stone, Matsuo, NEC Tokin, Nichicon, and Rubycon, have pled guilty. Settlements with all but three defendants exceed $400 million. The case continues against the remaining defendants, UCC, NCC and Mitsui.

16 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 88 of 253 PageID# 11511

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Hartley LLP Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Jason Hartley P 25.50 $875.00 $22,312.50 Teresa Jones CA 627.00 $300.00 $188,100.00 Fatima Brizuela A 0.60 $415.00 $249.00 Karen Taggart CA 6.20 $375.00 $2,325.00 Tina Glover PL 1.60 $250.00 $400.00 Dylan McFarland OC 49.40 $750.00 $37,050.00

TOTALS 710.30 $250,436.50

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 89 of 253 PageID# 11512

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Hartley LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $143.96 Filing / Misc. Fees Overnight Delivery/Messengers Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $1,119.75 Litigation Fund Contributions $40,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $41,263.71 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 90 of 253 PageID# 11513

Exhibit A-17 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 91 of 253 PageID# 11514

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF RICHARD M. HAGSTROM IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Richard M. Hagstrom, hereby declare as follows:

1. I am Of Counsel at the law firm of Hellmuth & Johnson PLLC (“H&J”), 8050 West

78th Street, Edina, MN 55439. I submit this declaration in support of Indirect Purchaser Plaintiffs’

Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the

Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. H&J and I have acted as counsel for Indirect Purchaser Plaintiffs in this litigation

on an entirely contingent basis. The background and experience of H&J and its attorneys are

summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth H&J’s total hours and attorneys’ fee

lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel . This

includes work performed by H&J’s attorneys and professional staff, computed at H&J’s historical

hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by H&J through February 28,

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 92 of 253 PageID# 11515

2021 is 1085. The total lodestar for H&J is $606,311.00. H&J’s lodestar amount includes only

work assigned by Interim Co-Lead Counsel and performed by H&J for the benefit of the Indirect

Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly rates for

H&J’s attorneys and professional staff are the same as the usual and customary hourly rates

charged by H&J for its services. The total attorney and professional staff time reflected in this

declaration is based on H&J’s contemporaneous, daily time records regularly prepared and

maintained by H&J, as well as any reductions in H&J’s lodestar required by Interim Co-Lead

Counsel.

6. H&J complied with the instructions provided by Interim Co-Lead Counsel that set

forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by H&J in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which H&J now seeks compensation.

7. As detailed in Exhibit C, H&J has incurred a total of $63,770.17 in unreimbursed

costs and expenses in this litigation during the period through March 31, 2021, including

$60,000.00 in contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. H&J

advanced these costs and expenses with no assurance that such costs and expenses would be repaid.

H&J has only set forth costs and expenses incurred through March 31, 2021, in accordance with

the guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of H&J. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 93 of 253 PageID# 11516

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 27th day of April 2021 in Fort Myers Beach, FL.

~f/~16~~RICH~HAGSTR<:0

3 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 94 of 253 PageID# 11517

EXHIBIT A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 95 of 253 PageID# 11518 HELL~UTH II JOHNSON

HELLMUTH & JOHNSON COMPLEX LITIGATION PRACTICE

The Hellmuth & Johnson (“H&J”) complex litigation team of attorneys has represented both plaintiffs and defendants in many of the most challenging antitrust, consumer fraud, mass tort, MDL, class action and complex business litigation cases in venues across the United States and around the world. Our experience successfully resolving high-profile, high-exposure cases includes matters involving price-fixing, monopolization, unfair competition, consumer fraud, intellectual property, financial institutions, and sports law. H&J’s commitment to efficiency and efficacy is the cornerstone of client service that we provide in every matter.

H&J has recently earned from Forbes a “most recognized for” designation in “Antitrust and Competition Law.” In addition, H&J was recently named to the Forbes list of “America’s Top Trusted Corporate Law Firms” in the field of Antitrust and Competition Law.

Because we have represented both plaintiffs and defendants, our attorneys have developed keen insights and experience which allow us to provide unique perspectives and strategies in the representation of our clients. We are better able to understand and anticipate the objectives and tactics of opposing counsel, giving our clients a distinct advantage. We are particularly adept at avoiding unnecessary tasks and expenses in pursuit of the most favorable outcomes. H&J clients appreciate our commitment to try cases only when necessary to achieve the best possible result. If a trial is inevitable, our extensive experience, especially in complex matters, gives us a decided strategic advantage and enables us to utilize lean staffing all while delivering exceptional service and consistent results.

Our complex litigation group attorneys offer experience and in-depth knowledge across a wide range of industries, and utilize their subject-matter knowledge to determine how the specific needs of our clients in each case relate to the broader implications of any dispute. Our complex litigation team has extensive experience with careful and thorough investigation and evaluation of the facts and applicable law, and with novel approaches to help our clients achieve success.

ANTITRUST LITIGATION REGARDING DIRECT AND INDIRECT PURCHASERS

Our approach to antitrust matters is decidedly different from other firms. In addition to representing classes composed of individuals, businesses, and governmental entities, H&J has represented multi-national corporations, along with medium and small businesses as both plaintiffs and defendants. We are selective in the disputes we pursue and consistently position that litigation for success in the courtroom. H&J has found this approach yields the best results for our clients at the settlement table or at trial. We carefully consider the objectives and economic realities in every case, looking for the best way to achieve an outcome that meets the needs and expectations of our clients.

The experience and track record of our antitrust attorneys has been recognized in courts across the nation. We have reached settlements and judgments of approximately one billion dollars for our plaintiff clients, and we have successfully defended other clients in mitigating their most significant exposures. We have substantial experience both settling and trying the most challenging antitrust cases.

1 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 96 of 253 PageID# 11519 HELL~UTH II JOHNSON

Representative Experience of H&J Attorneys

In re Microsoft Antitrust Litigation, (MDL 1332 and Multiple State Class Cases). Represented indirect purchaser antitrust class action in federal MDL, and appointed co-lead counsel in several states including Minnesota, Iowa and Wisconsin, to represent separate state classes of indirect purchasers for Microsoft’s illegal monopolization of the markets for personal computer operating system, word processing and spreadsheet software. Consultant to Canadian counsel for the prosecution of a nationwide indirect purchaser class action against Microsoft. Settlements of these actions totaled nearly $1 billion.

In re Broiler Chicken Antitrust Litigation, 16-cv-8637 (N.D. Ill.). Represent foodservice providers that purchased raw and processed chicken in case asserting coordinated supply cuts and price fixing.

In re Interior Molded Doors Indirect Purchaser Antitrust Litigation, 18-cv-850 (E.D. Va.). Represent consumers that purchased interior molded doors in case asserting coordinated price increases among purported competitors in price fixing conspiracy.

In re Aftermarket Automotive Filters Antitrust Litigation, MDL 1957 (N.D. Ill.). Co-Lead counsel of indirect purchaser class.

In re NCAA Athletic Grant-In-Aid-Cap Antitrust Litigation, MDL 2541 (N.D. Cal.). Representation of student athletes to recover shortfalls from grants intended to cover the cost of college attendance.

In re DRAM Antitrust Litigation, MDL 1486 (N.D. Cal.). Representation of a nationwide class of indirect purchasers for conspiracy to fix prices.

In re TFT-LCD (Flat Panel) Antitrust Litigation, MDL 1827 (N.D. Cal.). Representation of a nationwide class of indirect purchasers of LCD products, as flat panel televisions and computer monitors, in this multi-district antitrust class action filed against the world’s leading manufacturers of thin-film transistor liquid crystal displays (TFT-LCD), and alleging that these companies engaged in a conspiracy to artificially inflate the prices of their LCD products.

In re Suboxone Antitrust Litigation, MDL 2445 (E.D. Pa.). Member of executive committee representing end- payors who alleged drug maker illegally sought to extend its drug monopoly and keep opiate addiction treatment off the market.

State of New Mexico, et al., v. Visa, Inc., et al. (New Mexico D. Ct., Santa Fe District). Special Assistant Attorney General to the State of New Mexico in case alleging payment card interchange fees violate state antitrust and consumer fraud laws.

In re Midwest Milk Monopolization Litigation, MDL 83 (W.D. Mo.). Represented milk cooperatives in defense of claims under Sections 1 and 2 of the Sherman Act.

In re Viega Copper Press Fitting Antitrust Litigation, Case No. 1:19-cv-00159 (M.D. Pa.). Representation of nationwide class of indirect purchasers for conspiracy to fix prices through the tying of carbon steel press fittings and copper press fittings under state antitrust and consumer fraud laws.

2 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 97 of 253 PageID# 11520 HELL~UTH II JOHNSON

CONSUMER FRAUD / DATA BREACH / FINANCIAL INSTITUTIONS / SPORTS LAW

The H&J complex litigation group attorneys have represented consumers, investors, and others as plaintiffs in consumer fraud, data breach, securities fraud, financial services, unfair competition, unfair business practices, product liability, mass tort, property rights, sports, and ERISA claims. While a significant portion of the class action cases are part of MDL or federal district court proceedings, H&J attorneys are also commonly involved in state court class actions across the country.

Representative Experience of H&J Attorneys

In re Intel Corp. CPU Marketing, Sales Practices and Products Liability. Litigation, MDL 2828 (D. Or.). Member of the Interim Plaintiffs’ Steering Committee appointed to represent the interests of all Entity Plaintiffs nationwide for claimed security vulnerabilities in Intel’s processors that may be exploited to permit unauthorized access to stored confidential information.

In re Volkswagen “Clean Diesel” Marketing Sales Practices and Products Liability Litigation, MDL 2672 (N.D. Cal.). Member of discovery team representing consumers defrauded by concealment of software which defeated clean air technology under normal vehicle operation.

In re NHL Concussion Injury Litigation, MDL 2551 (D. Minn.). Executive committee member representing retired players concerning the devastating long-term brain injuries including CTE, resulting from repeated concussive and sub-concussive blows sustained when playing in the NHL.

In re CenturyLink Residential Customer Billing Disputes Litigation, MDL 1795 (D. Minn.). Executive committee member representing class for unlawful sales and billing practices in consumer fraud action.

H&T Fairhills, Ltd., et. al. c. Alliance Pipeline, L.P., 19-cv-01095 (D. Minn.). Lead counsel representing land interest holders in ND, MN, IA and IL in a class action involving the failure to pay those land interest holders compensation for damages caused by construction and maintenance of natural gas pipeline.

In re Target Corporation Customer Data Security Breach Litigation, MDL 2522 (D. Minn.). Member of lead counsel Daubert briefing team.

Haritos, et al. v. American Express Financial Advisors, (D. Ariz.). Represented consumers who purchased financial plans tainted by conflicts of interest.

In re NCAA Student Athletic Concussion Litigation, MDL 2492 (N.D. Ill.). Represented student athletes regarding long-term effects of repetitive concussive and sub-concussive blows.

In re Boston Scientific Corporation Securities Litigation, (D. Mass.). Member of lead counsel team in case asserting violations of the Private Securities Litigation Reform Act related to misleading or false statements regarding a medical device recall.

Rupp, et al. v. Thompson et al. (Minnesota Corn Processors) (Minn. Dist. Ct.). Represented unit holders in class action asserting breach of fiduciary duty and self-dealing against former officers and directors of an agricultural co-operative.

3 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 98 of 253 PageID# 11521 HELL~UTH II JOHNSON

In re Medtronic Securities Litigation. (D. Minn.). Represented securities purchasers alleging misrepresentations and omissions regarding adverse outcomes relating to medical device.

Menzel v. Beneficial Loan & Thrift Co. (Minn. Dist. Ct.). Represented financial institutions in consumer class action by loan customers alleging improper addition of points to loan principal.

Nathan, et al. v. Whirlpool Corp., 3:19-cv-00226 (D. Ohio). Represent putative class of consumers who purchased high performance KitchenAid blenders and allege violations of state consumer laws and breach of warranty claims for misrepresentations concerning the performance capabilities of its blenders.

Barclay, et al., v. ICON Health & Fitness, Inc. et al., 0:19-cv-02970 (D. Minn.). Represent putative class of fitness equipment purchaser consumers alleging violations of state consumer laws and breach of warranty claims for misleading performance representations in the sale of treadmills.

Taqueria El Primo LLC et al. v. Farmers Ins. Co., 19-cv-03071 (D. Minn.). Represent putative class of auto insurance consumers alleging violations of state consumer laws, breach of contract and declaratory judgment against auto insurance provider for no-fault auto insurance violations in its sales practices.

Bechtel v. Fitness Equipment Services, LLC, 1:19-cv-00726 (D. Ohio). Represent putative class of fitness equipment purchaser consumers alleging violations of state consumer laws and breach of warranty claims for misleading performance representations in the sale of treadmills.

Camden Asset Management, L.P. v. Sunbeam Corp. (S.D. Fla.). Represented debenture holders in class action based on company’s improper early recognition of sales to boost quarterly reported results.

EMPLOYMENT LAW

H&J attorneys are at the forefront of cutting-edge employment issues in the context of class and collective action claims. We act intelligently and proactively every step of the way helping to identify the best options for resolving difficult and challenging conflicts and balancing the financial and emotional costs surrounding these disputes. Our experience in jurisdictions throughout the country involves success in settling and trying class claims involving independent contractor issues, ERISA, donning and doffing, discrimination, misclassification from overtime, and other wage and hour disputes.

Representative Experience of H&J Attorneys

In re FedEx Ground Package System Inc. Employment Practices Litigation, MDL 1700 (N.D. Ind.). Member of Plaintiff’s Steering Committee team representing misclassified package delivery drivers nationwide. Successfully challenged FedEx’s independent contractor model in multiple cases brought under federal and state wage and hour laws and ERISA, leading to multi-million dollar class and aggregate settlements.

DeKeyser, et al. v. ThyssenKrupp Waupaca, Inc., 1:08-cv-00488 (E.D. Wisc.). Class counsel in wage and hour case challenging foundry’s practice of not compensating workers for pre- and post-shift work.

Garner, et al. v. Butterball, LLC, et al., 4:10-cv-01025 (E.D. Ark.) Class counsel for Arkansas poultry processing workers who were not paid for time spent performing work before and after paid shifts. Obtained $4.25 million settlement and change in employer practices.

4 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 99 of 253 PageID# 11522 HELL~UTH II JOHNSON

Daud, et al. v. Gold’n Plump Poultry, Inc., 06-cv-4013 (D. Minn.). Successfully represented employees facing religious discrimination in the workplace, leading to a $1.35 million settlement and change in practices.

Frank, et al. v. Gold’n Plump Poultry, Inc., 04-cv-1018 (D. Minn.) Class counsel for Minnesota and Wisconsin poultry processing workers who were not paid for time spent performing work before and after paid shifts. Settlement resulted in change of practices and $2.65 million monetary settlement for employees.

5 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 100 of 253 PageID# 11523

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Hellmuth & Johnson, PLLC Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Richard Hagstrom OC 146.70 $980.00 $143,766.00 Nicholas Kuhlmann A 179.50 $740.00 $132,830.00 Gregory Otsuka P 447.30 $300.00 $134,190.00 Gregory Otsuka P 118.20 $760.00 $89,832.00 Nate Prosser P 77.60 $740.00 $57,424.00 Michael Srodoski A 9.30 $430.00 $3,999.00 Heidi Bassett A 2.40 $300.00 $720.00 Faline Williams A 68.50 $330.00 $22,605.00 Joseph Beckman P 35.50 $590.00 $20,945.00

TOTALS 1085.00 $606,311.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 101 of 253 PageID# 11524

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Hellmuth & Johnson, PLLC Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $35.00 Filing / Misc. Fees $2.00 Overnight Delivery/Messengers $0.00 Photocopying $0.00 Postage $26.35 Service of Process Fees $0.00 Telephone / Fax $16.17 Transportation / Meals / Lodging $3,690.65 Litigation Fund Contributions $60,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $63,770.17 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 102 of 253 PageID# 11525

Exhibit A-18 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 103 of 253 PageID# 11526

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF CHRISTOPHER D. JENNINGS IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN A WARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Christopher D. Jennings hereby declare as follows:

1. I am a litigation partner at the Johnson Firm. I submit this declaration in support of

Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees, Reimbursement of

Expenses, and Service A wards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of the Johnson Firm and its class

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 438.90. The total lodestar for my firm is $142,077.50. My firm's lodestar amount Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 104 of 253 PageID# 11527

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm’s attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm’s contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm’s lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $20,000 in unreimbursed

costs and expenses in this litigation through March 31, 2021, including $20,000 in contributions

to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these costs and

expenses with no assurance that such costs and expenses would be repaid. My firm has only set

forth costs and expenses incurred through March 31, 2021, in accordance with the guidelines

established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 105 of 253 PageID# 11528

Executed this 26th day of April 2021 in Little Rock, Arkansas.

0~1h0~cs __, Christopher D. Je~ ings Arkansas Bar No. 2006306 JOHNSON FIRM 610 President Clinton A venue Suite 300 Little Rock, Arkansas 72201 T: (501) 372-1300 F: (888) 505-0909 E: [email protected]

3 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 106 of 253 PageID# 11529

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 107 of 253 PageID# 11530

BIOGRAPHY

The Johnson Firm is a nationally focused class action, mass tort, and personal injury law firm. The firm’s mission centers on providing high-value legal services and access to justice to those injured or otherwise harmed. Founded with the express intention of improving on the traditional law firm model, the Johnson Firm utilizes cutting-edge technology to make its services more efficient and cost-effective. Since its inception, the firm’s attorneys have been locally and nationally recognized for their abilities by their peers and enjoy membership in such prestigious organizations as the American Board of Trial Advocates and the National Trial Lawyers.

Class Action Litigation

Christopher D. Jennings is the managing litigation partner for the firm’s class action practice. His practice concentrates on complex litigation and representing consumers, businesses, and governmental entities in individual and class action antitrust, consumer protection, derivative, products liability, and federal securities cases. Mr. Jennings has prosecuted numerous individual, mass tort, and class cases in state and federal courts throughout the nation.

In the Antitrust arena, Mr. Jennings has taken an active role in assisting in the prosecution of several cases: In re TFT-LCD (Flat Panel) Antitrust Litigation, MDL 1827 (N.D. Cal.) (indirect purchaser settlements totaling $1.1 billion); In re SRAM (Static Random Access Memory) Antitrust Litigation, MDL 1819 (N.D. Cal.) (indirect purchaser settlements totaling $41.3 million); In re Transpacific Passenger Air Transportation Antitrust Litigation, MDL 1913 (N.D. Cal) (indirect purchaser settlements totaling $147 million to date); In re Flat Glass Antitrust Litigation (II), MDL 1942 (W.D. Pa.) (direct purchaser settlements totaling $22 million); In re Packaged Ice Antitrust Litigation, MDL 1952 (E.D. Mich.) (direct purchaser settlements totaling $26.5 million); and Rigo v. Kason Industries, et al., Case No. 3:11-CV-00064-MMA (S.D. Ca.) (co-lead counsel in indirect purchaser settlement of $720,000). Mr. Jennings and the firm are currently assisting in the prosecution of In re CRT (Cathode Ray Tube) Antitrust Litigation, MDL 1917 (N.D. Cal.) (indirect purchaser settlements totaling over $576 million to date); In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation, Case No. 3:18-cv-00850 (E.D. Va.); and In re: Hard Disk Drive Suspension Assemblies Antitrust Litigation, Case No. 3:19-md-2918-MMC (N.D. Cal.). Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 108 of 253 PageID# 11531

In the Consumer arena, Mr. Jennings has taken an active role in leading and assisting the prosecution of several class action cases involving the telecommunications, agricultural, banking, and healthcare industries. These cases have primarily focused on general consumer protection, data breach, and products liability causes of action.

For example, two telecommunications class cases Mr. Jennings has litigated resulted in settlements where approximately $61 million in total relief was made available to class members. Of these, Mr. Jennings served as lead counsel in a case involving wireless cramming charges resulting in settlement of approximately $17.1 million in available relief. Tyler v. Alltel Corp., et al., Case No. 4:07-CV-00019-JLH (E.D. Ark.). Mr. Jennings has also successfully litigated class issues on appeal having obtained favorable decisions affirming orders granting class certification and reversing orders denying class certification involving telecommunications carriers. See, e.g., Rosenow v. Alltel Corp., 358 S.W.3d 879, 2010 Ark. 26 (2010); DIRECTV, Inc. v. Murray, 423 S.W.3d 555, 2012 Ark. 366 (2012).

Mr. Jennings has also assisted the prosecution of agricultural products cases including In re Tyson Foods Consumer Litigation, MDL 1982 (D. Md.) (settlement totaling $5 million); In re Genetically Modified Rice Litigation, MDL 1811 (E.D. Mo.) ($750 million global settlement); and In re Syngenta AG MIR 162 Corn Litigation, MDL 2591 (D. Kan.) ($1.5 billion global settlement). In the Genetically Modified Rice litigation his team successfully opposed German holding company Bayer AG's jurisdictional challenges. In re Genetically Modified Rice Litigation, 576 F.Supp.2d 1063 (E.D. Mo. 2008).

Mr. Jennings currently serves as co-lead or class counsel in a number of bank cases involving improper overdraft and NSF fees pending in state and federal courts throughout the nation. Representative matters include: Louden, et al. v. Arvest Bank, Case No. 60CV-19-5520 (Pulaski County Circuit Court, Arkansas); Beaty v. First Community Bank, Case No. 60CV-20-997 (Pulaski County Circuit Court, Arkansas); Holt v. Community America Credit Union, Case No. 4:19- cv-629-FJG (W.D. Mo.); Walkingstick, et al. v. Simmons Bank, Case No. 6:19-cv-03184-RK (W.D. Mo.); Choy v. Space Coast Credit Union, Case No. 052019-CA39839 (Brevard County Circuit Court, Florida); Townsley v. Atlantic Union Bank, Case No. 3:19-cv-00849-JAG (E.D. Va.); Flowers v. Michigan First Credit Union, Case No. 2020-180019-CK (Oakland County Circuit Court, Michigan); Terrell, et al. v. Fort Knox Union Federal Credit Union, No. 19-CI-01281 (Hardin County Circuit Court, Kentucky) (settlement of $4.5 million); Graves v. Old Hickory Credit Union, Case No. 19- 0475-II (Davidson County Chancery Court, Tennessee) (settlement of $500,000); Tisdale v. Wilson Bank & Trust, Case No. 19-400-BC (Davidson County Chancery Court, Tennessee) (settlement of $550,000).

Mr. Jennings currently serves as co-lead or class counsel in multiple data breach cases including: Sherwood, et al. v. The Methodist Hospitals, Inc., Case No. 45D11-1911-PL-696 (Lake County Superior Court, Indiana); Martinez, et al. v. Presbyterian Healthcare Services, Case No. D- 22-cv-2020-1578 (Bernalillo County District Court, New Mexico); Slos v. Select Health Network, Inc., Case No. 71-D05-2002-PL-060 (St. Josephy County Superior Court, Indiana); In re Banner Health Data Breach Litigation, Case No. 2:16-cv-02696-PHX (D. Ariz.) ($6 million settlement); Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 109 of 253 PageID# 11532

Gordon, et al. v. Chipotle Mexican Grill, Inc., Case No. 1:17-cv-1415-CMA (D. Col.) (settlement value of $1.6 million in available relief); Orr, et al. v. Intercontinental Hotel Groups, PLC, et al., Case No. 1:17-cv-01622-MLB (N.D. Ga.) ($1.55 million settlement); McKenzie, et al. v. AllConnect, Inc., Case No. 5:18-cv-00359-JMH (E.D. Ky.) (settlement value of $1.6 million in available relief).

Mr. Jennings has also taken an active role in leading and assisting the prosecution of several class action cases involving consumer products. Representative matters include: Buford v. Smitty’s Supply, Inc., et al., Case No. 1:19-cv-82-LPR (E.D. Ark.); In re Intel Corp. CPU Marketing, Sales Practices and Products Liability Litigation, Case No. 3:18-md-2828 (D. Or.); and Albright, et al., v. Sherwin-Williams Company, et al., Case No. 1:17-cv-2513-SO (N.D. Ohio).

In the Mass Tort Arena, Mr. Jennings has successfully pursued claims involving defective medical devices and pharmaceutical products. Representative litigations include: In Re Biomet M2A Magnum Hip Implant Products Liability Litigation, MDL 2391 (N.D. Ind.); In re DePuy Orthopaedics, Inc., ASR Hip Implant Products Liability Litigation, MDL 2197 (N.D. Ohio); In re Stryker Rejuvenate and ABG II Hip Implant Products Liability Litigation, MDL No. 2441 (D. Minn.); In re Invokana (canagliflozin) Products Liability Litigation, MDL 2750 (D. N.J.); and In re Xarelto Products Liability Litigation, MDL 2592 (E.D. La.).

Mr. Jennings is a native of Little Rock, Arkansas. In 2001, Mr. Jennings obtained his Bachelor of Arts Degree in Political Science from the University of Arkansas with a minor in History. In 2005, he earned a Masters in Public Administration (MPA) degree from the University of Arkansas with an emphasis on administrative law. In 2006, Mr. Jennings earned his Juris Doctorate from the William H. Bowen School of Law at the University of Arkansas in Little Rock.

Mr. Jennings is admitted to practice in all Arkansas state courts, the Eastern and Western Districts of Arkansas, the District of Colorado, and the 8th Circuit Court of Appeals. He has also been admitted to practice on an individual case-basis in numerous state and federal district courts throughout the country.

Mr. Jennings is a member of the American Associate of Justice, the National Trial Lawyers, Public Justice, and the National Association of Securities and Consumer Attorneys (NASCAT). He recently served as a member of the NASCAT committee on the Federal Rules of Civil Procedure. He is also a fellow of the Litigation Council of America and has been named a Mid-South Super Lawyers Rising Star in class action and mass tort litigation from 2012 to 2019. In 2020, he was named a Mid-South Super Lawyer in class action and mass tort litigation.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 110 of 253 PageID# 11533

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Johnson Firm Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Christopher Jennings P 30.40 $650.00 $19,760.00 Michelle Cossio A 407.00 $300.00 $122,100.00 Jacey Bittle PL 1.20 $150.00 $180.00 Kyla Bishop LC 0.30 $125.00 $37.50

TOTALS 438.90 $142,077.50

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 111 of 253 PageID# 11534

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Johnson Firm Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees Overnight Delivery/Messengers Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging Litigation Fund Contributions $20,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $20,000.00 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 112 of 253 PageID# 11535

Exhibit A-19 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 113 of 253 PageID# 11536

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF DANIEL R. KARON IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Daniel R. Karon hereby declare as follows:

1. I am a partner at the law firm of Karon LLC. I submit this declaration in support of

Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees, Reimbursement of

Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

.and wouJd oompe-tently te-stify the-reto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Karon LLC and its attorneys are

-summariz.ed in the firm r-esume- attached h-e-r-eto as Exhibit A

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and prof-e:s-sional-staff, comput-ed at my firm~-s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

2&, 2021 i-s 23-.50. The total lode-star for my firm i0s $-l~,740. My firm'-s lodestar amount includes Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 114 of 253 PageID# 11537

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rate-s for my firm' -s attorneys and professional -staff are the- -same a-s the- usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm's contemporaneous, daily time records regularly prepared

and maintainoo by my firm, a:s w-eU a-s any reductions in my firm'-s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

-s€t forth the· guidelil1€S for the-categories of work and hourly rat-es permitted to re included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of-S€I"Vices for which my firm now wek-s comp€llsation.

7. My firm has not incurred any unreimbursed costs and expenses in this litigation

through March 31, 2021.

8. l declare under penalty of perjury that the- foregoing i-s true- and correct.

Executed this 30th day of April, 2021 in Cleveland, Ohio.

Daniel R. Karon KaronLLC 700 W. St. Clair Ave., Suite 200 Cleveland, OH 44113 (216) 622-1851 [email protected] Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 115 of 253 PageID# 11538

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 116 of 253 PageID# 11539

KARON

KARON LLC 700 W. St. Clair Ave., Suite 200 Cleveland, OH 44113–1998 Telephone: (216) 622–1851 Facsimile: (216) 241–8175 E–mail: [email protected] Web: www.karonllc.com

SUMMARY

Karon LLC specializes in antitrust, consumer–fraud, and wage-and-hour litigation. The firm represents individuals in antitrust, consumer-fraud, wage-and-hour, and other class-actions and has represented domestic and international corporations in domestic and international antitrust class- action matters. The firm also defends corporations in consumer-fraud and antitrust class actions.

Mr. Karon teaches complex litigation and class-action law at the University of Michigan Law School and taught complex litigation at Columbia Law School. He has also been a lecturer in law at Cleveland State University’s Cleveland-Marshall College of Law. He lectures on class-action law at multiple other law schools and serves on Loyola University Chicago School of Law’s Institute for Consumer Antitrust Studies’ U.S. Advisory Board. He chairs the ABA’s National Institute on Class Actions, writes a bimonthly column for Law360, was an editorial board member and contributing author to the ABA’s Litigation Section’s Class Actions Today-Jurisdiction to Resolution magazine, was a member of the Ohio Association of Justice’s Board of Trustees, and served as an editorial board member for the Ohio Academy of Justice’s Ohio Trial magazine. He has published multiple law review and bar journal articles on class-action topics, and he lectures nationally on class actions for the ABA and other bar associations.

In addition to various antitrust and consumer-fraud class actions, Mr. Karon was extensively involved in the LCD–TFT Indirect Purchaser Antitrust Litigation, No. C07-1827 (N.D. Cal. 2007) (nationwide price-fixing class action that settled for $1.1 billion), Vitamins Direct Purchaser Antitrust Litigation, MDL 1285 (D.C. 2002) (nationwide price-fixing class action that resolved for $2 billion), NASDAQ Market- Makers Antitrust Litigation, No. 94 Civ. 3996 (S.D.N.Y. 1994) (nationwide price-fixing class action that settled for $1.027 billion), Cathode Ray Tubes (CRT) Antitrust Litigation, MDL 1917 (N.D. Cal. 2007) (nationwide price-fixing class action that settled for $500 million), Monosodium Glutamate Antitrust Litigation (nationwide price-fixing class action that settled for $130 million), Methionine Antitrust Litigation, No. 00-MDL-1328 (D. Minn. 2000) (nationwide price-fixing class action that settled for $101 million), and Sorbates Direct Purchaser Antitrust Litigation, No. C 98-4886 (N.D. Cal. 1998) (nationwide price-fixing class action that settled for $94.5 million). He serves or served as lead counsel in multiple class-action cases, including Magnesium Oxide Antitrust Litigation, No. 2:10-cv-05943 (D.N.J. Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 117 of 253 PageID# 11540

2011), Aftermarket Sheet Metal Indirect Purchaser Antitrust Litigation, No. 2:09-cv-00852 (E.D. Wis. 2009), City of Lorain v. Medical Mutual Insurance Co., No. 17 CV 191670 (Lorain Cty. Cir. Ct. 2017), Dairy Indirect- Purchaser Antitrust Litigation, No. 2:08-MD-100 (E.D. Tenn. 2008), Johnson v. Evangelical Lutheran Church of America, No. 11-00023 (D. Minn. 2011), Schwartz v. Avis Rent-A-Car Corp., No. 11-4052 (D.N.J. 2011), Savett v. Great American, No. 20 cv 42 (N.D. Ohio 2020), Klein v. Budget Rent-A-Car Group, No. 12-7300 (D.N.J. 2012), Bausch & Lomb Contact Lens Product Liability Litigation, No. 2:06-MN-7777 (D.S.C. 2010), Roth v. Life Time Fitness, No. 16-2476 (D. Minn. 2016), Grissom v. Antero Energy Corp., 2:20-cv-02028 (S.D. Ohio 2020), Savett v. SP Plus, No. 17 CH 2437 (Cook Cty. Chancery Ct.), Ezold v. Tracfone Wireless, Inc., 1:2020 cv 21346 (S.D. Fla. 2020), and Schwartz v. Alltel Corp., No. 86810 (Cuyahoga Cty. Common Pleas). He is on the executive committee in the Beef Antitrust Litigation, 19- cv-1222 (D. Minn.), was discovery co-chair in the Bulk Graphite Antitrust Litigation, No. 02-6030 (D.N.J. 2006), class-certification co-chair in the Pressure Sensitive Labelstock Antitrust Litigation, MDL 1556 (2006), and briefing co-chair in the EPDM Antitrust Litigation, 3:3mdl1542 (D. Conn. 2003), and Carbon Black Antitrust Litigation, No. 03-10191 (2003).

Mr. Hollowell focuses his national practice on antitrust, consumer fraud, employment, and securities fraud class action litigation. He has won multiple bench and jury trials and has successfully argued federal- and state-court appeals.

Mr. Hollowell has represented and advised clients in proceedings before state and federal courts in Alabama, California, Delaware, Hawaii, Illinois, New Jersey, New York, Ohio, Oklahoma, Texas, Puerto Rico, Wisconsin, and the U.S. Virgin Islands. He began his career with one of the premier trial firms in Cleveland, Ohio. He next handled complex commercial litigation matters for two sophisticated investor groups with approximately $600 million in assets throughout the United States and Europe. After that, he led a statewide practice group for one of the largest litigation firms in the country.

Mr. Hollowell has represented large businesses and insurance companies in high-value cases in various practice areas. He has also lectured and written extensively, including co-authoring an article that appeared in a national publication and reappeared in a national online journal with 45,000 monthly readers. Beau continues to write articles discussing recent trends, while also presenting seminars on numerous topics at national and regional conferences.

After earning his Bachelor of Arts in English from Westminster College in 2002, Beau graduated from Case Western Reserve University School of Law in 2006. The School of Law awarded him the Paul J. Hergenroeder Award and CALI Award for his achievement as top student in Trial Tactics. He also served as a research assistant for two nationally known and published professors: Professor William Carter (dean of the University of Pittsburgh School of Law), whose articles have been published in many well-known journals, including the Harvard Civil Rights-Civil Liberties Law Review, and Professor Peter Gerhart (former dean of Case Western’s Law School). Through Case Western’s International War Crimes Lab, Beau also prepared a memorandum addressing the jurisdiction of military commissions to preside over trials in Guantanamo Bay Naval Base—a topic debated nationally in many fora, including National Public Radio. Beau prepared this memorandum at the direction of the United States Department of Defense.

Mr. Hollowell is a member of various professional bar associations and was selected to serve as president of the New Partners Board for the Cleveland Hearing and Speech Center. The Center is the nation’s oldest freestanding speech center and is Northeast Ohio’s only nonprofit organization 2 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 118 of 253 PageID# 11541

directed solely to serving those with special communication needs. Beau has also participated in Big Brothers of America. Recently, Westminster College selected Beau to serve on its Alumni Council, where he emphasizes alumni relations and donations through the Council’s Annual Giving Committee, which committee the College selected Beau to chair.

Daniel R. Karon

EDUCATION

J.D., 1991 Michael E. Moritz College of Law, The Ohio State University Member, The Ohio State Journal on Dispute Resolution Quarterfinalist, First-Year Moot Court Competition

B.A., Speech Communication and Rhetorical Studies, 1988 Certificate, Jewish Studies, 1988 Indiana University-Bloomington Dean’s List, 1984–1987

TEACHING EXPERIENCE

Lecturer in Law, University of Michigan Law School January 2020–Present Complex litigation and class-action law

Lecturer in Law, Columbia Law School January 2018–August 2019 Complex litigation and class-action law

Lecturer in Law, Cleveland-Marshall College of Law, Cleveland State University February 2005–2007 Class-action law

Lecturer, Michael E. Moritz College of Law, The Ohio State University February 2008–Present Class-action law

Lecturer, Columbia Law School February 2013–February 2017 Class-action law

Lecturer, University of Michigan Law School October 2018 Class-action law

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Lecturer, Vanderbilt Law School April 2013 Class-action law

Lecturer, Notre Dame Law School February 2015 Class-action law

Lecturer, Tulane Law School November 2013 Class-action law

Lecturer, University of San Francisco School of Management January 2021 Class-action law

Lecturer, University of Georgia School of Law November 2015 Class-action law

Lecturer, Benjamin N. Cardozo School of Law, Yeshiva University April 2014 Class-action law

Lecturer, Loyola University Chicago School of Law November 2013, February 2019, October 2020 Class-action law

BAR ADMISSIONS

United States Court of Appeals for the Third Circuit 2016

United States District Court for the Eastern District of Michigan, 2015

United States Court of Appeals for the Sixth Circuit 2013

United States District Court for the Southern District of Ohio, 2004

United States District Court for the Northern District of Ohio, 1998

United States Court of Appeals for the Seventh Circuit, 1995

United States District Court for the Northern District of Illinois, 1991

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Ohio, 1997

Illinois, 1991

CLASS-ACTION EXPERIENCE

Karon LLC, Cleveland, OH Owner, 2014–Present

Goldman Scarlato Karon & Penny, P.C., Cleveland, OH Owner, 2002–2014

Gallagher Sharp Fulton & Norman, Cleveland, OH Attorney, 2000–2002

Law Offices of Daniel R. Karon, Cleveland, OH Owner, 1998–2000

Much Shelist Freed Denenberg Ament & Rubenstein, P.C., Chicago, IL Attorney, 1994–1998

PUBLICATIONS

Surefire Marketing Methods To Build Your Legal Practice, INT’L COMPARATIVE LEGAL GUIDES (Apr. 14, 2021)

Top 10 Techniques for Crafting a Dazzling Brief, INT’L COMPARATIVE LEGAL GUIDES (Apr. 14, 2021)

Simple Secrets for Writing a Killer Brief, INT’L COMPARATIVE LEGAL GUIDES (Apr. 14, 2021)

In the room where it’s happening, CLEVELAND PLAIN DEALER (Apr. 11, 2021)

The Problem—and Opportunity—of Implicit Bias in the Bar, AMERICAN INNS OF COURT (Mar. 22, 2021)

What the Biden Administration Means for Class Actions, LAW360 (Feb. 11, 2021)

To Mask or Not to Mask? Not a Constitutional Question, THE CLS BLUE SKY BLOG—COLUMBIA LAW SCHOOL BLOG ON CORPORATIONS AND THE CAPITAL MARKETS, (Oct. 27, 2020)

Companies Should Not Illegally Profit From Our Pandemic Pain, LAW360 (Apr. 15, 2020)

Surefire Marketing Methods to Build Your Legal Practice, LAW360 (Jan. 28, 2020)

The Problem—and Opportunity—of Implicit Bias in the Bar, LAW360 (Oct. 2, 2019)

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Why Can’t We All Just Get Along?, 45:3 LITIGATION 8 (Winter 2019)

Ten Techniques for Crafting a Dazzling Brief, LAW360 (June 21, 2019)

“Can’t We All Just Get Along?” Civility Across the V., THE BENCHER (May/June 2019)

Simple Secrets for Writing a Killer Brief, LAW360 (Feb. 28, 2019)

Class Action Strategy & Practice Guide, Chapter 8, Managing Multiple Class and Enforcement Actions (2019)

Simple Secrets for Improving Your CLE, LAW360 (Nov. 14, 2018)

Kavanaugh and the Confirmation of Third-Branch Bias, OurFuture.org (Oct. 9, 2018)

It’s Prime Time for a Dose of Reality on Brett Kavanaugh, LAW360 (Aug. 2, 2018)

After Trump’s Policy Purges, Who Speaks for the Victims?, LAW360 (May 2, 2018)

Why Contempt for the CFPB Is a Big Business Mistake, LAW360 (Oct. 28, 2017)

How Plaintiffs and Defense Counsel Misperceive Each Other, LAW360 (Sept. 25, 2017)

Why “Class Action Attorney Fees” Are Such Dirty Words, NATIONAL ASSOCIATION OF LEGAL FEE ANALYSIS (July 18, 2017)

Why “Class Action Attorney Fees” Are Such Dirty Words, LAW360 (July 14, 2017)

Bundle Up Defense Counsel. Winter’s Coming, LAW360 IN-DEPTH (May 2, 2017)

Killing Class Actions Means Everybody Loses, THE CLS BLUE SKY BLOG—COLUMBIA LAW SCHOOL BLOG ON CORPORATIONS AND THE CAPITAL MARKETS, (Apr. 7, 2017)

The Death of Class Actions?, ACSBLOG, AMERICAN CONSTITUTION SOCIETY (Mar. 3, 2017)

Killing Class Actions Means Everybody Loses, LAW360 (Mar. 17, 2017)

The “Fairness” in Class Action Litigation Act, 42:4 LITIGATION 8 (Summer 2016)

Dow Chemical’s Post-Scalia Settlement is a Spin Doctor’s Delight, THE NATIONAL LAW JOURNAL, SUPREME COURT BRIEF (Apr. 25, 2016)

Dow Chemical’s Post-Scalia Settlement is a Spin Doctor’s Delight, THE NATIONAL LAW JOURNAL (Apr. 25, 2016)

Federal Class-Action Reform Effort Courts Serious Risks, CLEVELAND PLAIN DEALER (Nov. 20, 2015)

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Is it CAFA or Kafka? Effectively Pleading Multistate Class-action cases after the Class Action Fairness Act, THE OHIO ASSOCIATION FOR JUSTICE QUARTERLY 21 (Oct. 2014)

Reflections from the 2013 National Institute on Class Actions, 24 ABA’s CLASS ACTIONS & DERIVATIVE SUITS 1 (Fall 2013)

Suspicionless Strip Searches—What's Next?, 39:1 LITIGATION 8 (Winter 2013)

Ripped from the Headlines—Ten Lawyers Look at the Story, 38:2 LITIGATION 25 (Winter 2012)

“T’was Three Years After Twombly and All Through the Bar, Not a Plaintiff Was Troubled From Near or From Far.” The Unremarkable Effect of the U.S. Supreme Court’s Re-expressed Pleading Standard in Bell Atlantic Corp. v. Twombly, 44 U.S.F. L. REV. 571 (2010)

The Unremarkable Effect of Bell Atlantic Corp. v. Twombly on Pleading Class–Action Complaints, 11:2 ABA’s COMM’L & BUS. LITIG. 6 (Spring 2010)

Is it CAFA or Kafka, AAJ’s TRIAL MAGAZINE 24 (July 2009)

ABA’s Consumer Protection Law Developments, Chapter 5 State Consumer Law, § 36 Ohio (2009).

“When Congress Gives You Lemons . . .” Plaintiffs’ Attorneys are Forced by the Class Action Fairness Act to Devise Innovative New Ways to Prosecute Interstate Class Actions, PLAINTIFF MAGAZINE 1 (Feb. 2008)

Multi–State Class Actions After CAFA—Preserving Consumers’ Rights by Pleading Creatively, ABA’s CLASS ACTIONS TODAY 9 (2007)

“How Do You Take Your Multi–State, Class action Litigation? One Lump or Two?” Infusing State Class action Jurisprudence into Federal, Multi-State Class-Certification Analyses in a “CAFA-nated” World, 46 SANTA CLARA L. REV. 567 (2006)

Unjust Enrichment’s Application to Consumer Price fixing, Class action Claims, 16 ABA’s CLASS ACTIONS & DERIVATIVE SUITS 1 (Winter 2006)

Undoing the Otherwise Perfect Crime. Applying Unjust Enrichment to Consumer Price fixing Claims, 108 W. VA. L. REV. 395 (2005)

A Non-Class-action lawyer’s Guide to Ohio Consumer Class Actions—Understanding the Basics and Recognizing Opportunities, 14:3 OHIO TRIAL 26 (2005)

Price Fixing and Market Allocation—What to Avoid, What to Watch For, 2.2 ABA’S ANTITRUST COUNSELOR 1 (2005)

“Your Honor, Tear Down that Illinois Brick Wall!” The National Movement Toward Indirect Purchaser Antitrust Standing and Consumer Justice, 30 WM. MITCHELL L. REV. 1351 (2004)

Price Fixing, Market Allocation and Bid Rigging Conspiracies: How to Counsel Your Clients to Detect Violations and Inform You of Potential Claims, 25 AMER. J. TRIAL ADVOC. 241 (2002) 7 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 123 of 253 PageID# 11546

Collusion Central. Helping Your Clients Deal with Price Fixers, 11:3 ABA’S BUS. L. TODAY 9 (2002)

A Practitioner’s Primer on Securities Fraud Class Action Litigation, 69:6 CLEV. BAR J. 8 (1998)

Kicking Our Gift Horse in the Mouth—Arbitration and Arbitrator Bias: Its Source, Symptoms and Solutions, 7 OHIO ST. J. ON DISP. RESOL. 315 (1992)

Winning Isn’t Everything, It’s the Only Thing. Violence in Professional Sports: The Need for Federal Regulation and Criminal Sanctions, 25 IND. L. REV. 147 (1991)

SPEAKING ENGAGEMENTS

Speaker, “Quarterly Section Meeting—Consumer Law,” Ohio Association for Justice, April 27, 2021

Speaker, “The Not-Unconstitutionality of Mask Mandates,” Irish-American Law Society, April 21, 2021

Speaker, “Business Development & Networking: Advice on Steps to Take Today,” Cleveland Metropolitan Bar Association, February 22, 2021

Speaker, “New Trends in Consumer Law,” Ohio Association for Justice, February 11, 2021

Speaker, Kappa Alpha Pi Pre-Law Fraternity, University of Michigan, November 17, 2020

Program Chair and Moderator, ABA’s 24th Annual National Institute on Class Actions, “Interview with Rep. Katie Porter and Rich Cordray: A Life in Class Actions,” October 13–15, 2020, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, “Ethical Issues in Class Actions,” NCLC Annual Consumer Rights Litigation Conference, Boston, MA, November 14–17, 2019, sponsored by the National Consumer Law Center

Program Chair and Moderator, ABA’s 23rd Annual National Institute on Class Actions, “Second to None. Class Actions 101,” “Write to the Point. Class Actions 201,” Nashville, TN, October 17–18, 2019, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Speaker, AAJ’s 2019 Annual Convention, “The Craft of Beautiful Legal Writing,” San Diego, CA, July 28, 2019, sponsored by American Association for Justice

Program Chair and Moderator, “Who Needs Playhouse Square?” Class Certification from A(rsenio) to (O)Z: A Three-Act Play,” Cleveland, OH, March 13, 2019, sponsored by the William K. Thomas Inns of Court

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Speaker, “Class Actions 101,” January 17, 2019, New York, NY, sponsored by the New York State Bar Association

Panelist, “Why Antitrust Matters,” October 30, 2018, Cleveland, OH, sponsored by the ABA’s Antitrust Section

Program Chair and Moderator, ABA’s 22nd Annual National Institute on Class Actions, “Second to None. Class Actions 101,” “Write to the Point. Class Actions 201,” Chicago, IL, October 18–19, 2018, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, GMA Legal Conference, “What in the World was He Thinking? A Look Inside the Mind of a Plaintiff’s Attorney, and How to Respond,” February 26–27, 2018, sponsored by the Grocery Manufacturers Association

Plenary Moderator, ABA’s Corporate Counsel Seminar, “Class Actions Scared Straight: Real Class-Action Stories, Strategies, and Solutions from Both Sides of the ‘v.,’” La Quinta, CA, February 17, 2018, sponsored by the ABA’s Corporate Counsel Section

Panelist, ABA Environmental & Energy, Mass Torts, and Products Liability Litigation Committees’ Joint CLE Seminar, “Brave New World: Perspectives on the Regulatory and Legal Landscape One Year into Trump’s Administration,” January 27, 2018, Whistler, BC, sponsored by the ABA’s Environmental & Energy, Mass Torts, and Products Liability Litigation Committees

Panelist, Harris Martin Plaintiff Opioid MDL Conference, “Third-Party Payor, Class, and Hospital Claims,” January 8, 2018, sponsored by Harris Martin Program Chair and Moderator, ABA’s 21st Annual National Institute on Class Actions, “Debating the Language. Class Actions 101,” “Let’s Vote on It. Class Actions 201,” “Join the Writing Revolution. Class Actions 301,” “Build That Wall . . . or Maybe Not. H.R. 985 and the End of Class Actions?” Washington, DC, October 26–27, 2017, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Speaker, AAJ’s 2017 Annual Convention, “How to Grow Your Practice by Recognizing Antitrust Cases” and “The Art of Beautiful Legal Writing,” Boston, MA, July 22, 2017, sponsored by American Association for Justice

Speaker, AAJ Continuing Legal Education Conference, “The Future of Class Actions: Teamwork, Savvy Defense, and Smart Offense,” Nashville, TN, May 11, 2017, sponsored by American Association for Justice

Panelist, GMA 2017 Legal Conference, “Fighting Back Against Class Action Litigation,” San Diego, CA, February 27–28, 2017, sponsored by the Grocery Manufacturers Association

Panelist, OSBA Federal Courts & Practice Committee Bench Bar Conference, “Class Certification Analysis after Duke & Comcast, October 27–28, 2016, sponsored by the Ohio State Bar Association

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Program Chair and Moderator, ABA’s 20th Annual National Institute on Class Actions, “‘Coming Out!” It’s Class Actions 101,” “‘Box the Trifecta.’ Let’s Play Class Actions 301,” “‘From Mirage to Immense.’ The Genesis, Creation, and Evolution of Rule 23 with Professor Arthur Miller,” and “‘Hitting the Jackpot!’ A One-on-One Class-Action Conversation with Judge Richard Posner,” Las Vegas, NV, October 19–20, 2016, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, “No BigLaw? No Problem! How Small-Firm Plaintiff and Defense Lawyers Are Managing Some of the Largest Class-Action Litigation Matters,” May 27, 2016, sponsored by the ABA

Panelist, “Cross-Industry Interdisciplinary Summit on Class Actions,” New York, NY, April 11– 12, 2016, sponsored by American Conference Institute

Panelist, “Is this CAFA or Kafka? Multi-State Actions in a Time of Metamorphosis,” Litigation Section Annual Conference, Chicago, IL, April 14, 2016, sponsored by the ABA

Program Chair and Moderator, ABA’s 19th Annual National Institute on Class Actions, “‘Who Dat?!’ It’s the Return of Class Actions 101 and Class Actions 201” and “You Have a Choice, Picayune—‘Economic Loss’ or ‘No-Injury’ Class Actions. Either Way, Does a Legal Claim Exist?” New Orleans, LA, October 22–23, 2015, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Program Chair, “Antitrust for Non-Antitrust Lawyers: How to Grow Your Business by Recognizing New Opportunities,” National Teleseminar, January 15, 2015, sponsored by American Association for Justice

Program Chair and Moderator, ABA’s 18th Annual National Institute on Class Actions, “Second to None. Class Actions 101” and “Who Needs The Second City?” Class Certification from A(kroyd) to (Lovit)Z: A Three-Act Play,” Chicago, IL, October 23–24, 2014, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Lecturer, Ohio Association of Justice’s Annual Convention, “Class Actions for Non-Class Action Attorneys. How to Grow Your Business by Recognizing New Opportunities,” Columbus, OH, May 8, 2014, sponsored by Ohio Association for Justice

Panelist, Article III Standing and Rule 23(b)(3) Certification: Emerging Litigation Trends, December 3, 2013, National Teleseminar, sponsored by Strafford Publications

Program Chair and Moderator, ABA’s 17th Annual National Institute on Class Actions, “Listen Co-Counsel, You’ll Learn a Ton, It’s Time for Class Actions 101” and “‘Show Me the Money!!! . . . or Don’t.’ Cy Pres Recoveries, Requests for Attorneys’ Fees, and Does This Amount to a Hill of Beans?” Boston, MA, October 23–24, 2013, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, Ohio State Bar Association’s 2012 Great Lakes Antitrust Institute, “New Developments in Antitrust Law,” Columbus, OH, November 2, 2012, sponsored by the Ohio State Bar Association 10 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 126 of 253 PageID# 11549

Program Chair and Moderator, ABA’s 16th Annual National Institute on Class Actions, “‘The Class Definition that Works . . . or Does It?’ Strategies for Pleading and Attacking Class Definitions—The Most Basic and Most Ignored Step in a Class-action lawsuit’s Success or Failure,” Chicago, IL October 25, 2012, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Program Chair and Moderator, “Reexamining the Class Action Practice and Considering Where it—Indeed, We—Go From Here,” Chicago, IL, August 3, 2012, sponsored by the ABA

Moderator and Panelist, “Everything MDL. First-Hand Perspectives from MDL Panel Judges, MDL District Court Judges, and MDL Lawyers,” Cleveland, OH, July 25, 2012, sponsored by the Cleveland Metropolitan Bar Association and the Federal Bar Association, Northern District of Ohio Chapter

Panelist, “Litigating Class Actions Between Class Certification and Trial,” National Teleseminar, January 31, 2012, sponsored by Strafford Publications

Panelist, “Trends in Federal Circuit Class Certification Rulings,” National Teleseminar, January 19, 2012, Law Seminars International

Program Chair and Moderator, ABA’s 15th Annual National Institute on Class Actions, “The Practice that Never Sleeps: Reexamining the Class action Practice and Considering Where it— Indeed, We—Go From Here,” New York, NY, October 14, 2011, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, Wal–Mart v. Dukes, Practical Implications of the Supreme Court’s Landmark Class Action Ruling, National Teleseminar, June 30, 2011, sponsored by Law Seminars International Panelist, ABA’s 59th Annual Antitrust Law Spring Meeting, “Guilt by Association? Trade Associations, Cartel Investigations, and Twombly,” Washington, D.C., March 30, 2011, sponsored by the ABA’s Antitrust Law Section

Panelist, “Pleading and Defending Class Actions: Leveraging the Latest Developments in CAFA Removal Jurisdiction,” National Teleseminar, December 8, 2010, sponsored by Strafford Publications

Panelist, “Litigating Class Actions Between Class Certification and Trial,” National Teleseminar, November 2, 2010, sponsored by Strafford Publications

Program Chair and Moderator, ABA’s 14th Annual National Institute on Class Actions, “‘The Standard that Works . . . or Does It?’ Deciding Choice–of–Law and Reliance/Causation/ Deception Standards in Multistate, Consumer fraud Class actions After CAFA,” Chicago, IL, October 14, 2010, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, “Consumer Class action Litigation: Leveraging New Developments in Class Certification, Causation, and Reliance,” National Teleseminar, April 20, 2010, sponsored by Strafford Publications

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Panelist and Moderator, ABA’s 13th Annual National Institute on Class Actions, “A Funny Thing Happened on the Way to the Courthouse . . . I Had to Litigate an Arbitration Clause! Crafting, Opposing, and Arguing Arbitration Clauses and Class action Waivers in Three Scenes,” Washington DC, November 20, 2009, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist and Moderator, ABA’s 13th Annual National Institute on Class Actions, A Funny Thing Happened on the Way to the Courthouse . . . I Had to Litigate an Arbitration Clause! Crafting, Opposing, and Arguing Arbitration Clauses and Class action Waivers in Three Scenes, San Francisco, CA, October 30, 2009, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panelist, “Litigating Class Actions Between Class Certification and Trial,” National Teleseminar, August 11, 2009, sponsored by Strafford Publications Panelist, “It Ain’t Over Till it’s Over: Litigating Class Actions After Class Certification and Before Trial,” National Teleseminar, May 27, 2009, sponsored by ABA Litigation Section

Panelist, “Antitrust 101: Understanding, Pleading, and Defending Price fixing Claims,” ABA Brown Bag Teleseminar, February 18, 2009, sponsored by the ABA’s Section on Litigation

Panelist, “Pleading, Defending, and Settling Class Actions. Emerging Trends,” National Teleseminar, December 9, 2008, sponsored by Strafford Publications

Panelist, Ohio State Bar Association’s 2008 Antitrust Program, “When Opportunity Knocks . . . . Growing Your Business or Company’s Bottom Line by Recognizing When, Whether, and How to Pursue Class action, Price fixing Claims,” Columbus, OH, November 14, 2008, sponsored by the Ohio State Bar Association

Panelist and Moderator, ABA’s 12th Annual National Institute on Class Actions, “‘I Could Have Sworn It was CAFA, not Kafka!’ The Metamorphosis of Pleading, Defending, and Settling Multi- State Class Actions—A Surreal-Life, Three-Act Play,” New York, NY, November 7, 2008, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Lecturer, “Class Actions: Growing Your Business by Understanding the Basics and Recognizing Opportunities,” Cleveland, OH, October 31, 2008, sponsored by the Cleveland Bar Association

Panelist, “Pleading, Defending, and Settling Class Actions. Emerging Trends,” National Teleseminar, May 13, 2008, sponsored by Strafford Publications

Panelist, Ohio Association for Justice’s 2008 Annual Convention, “New Developments in Plaintiffs’ Antitrust Law,” Columbus, OH, May 9, 2008, sponsored by the Ohio Association for Justice

Lecturer, “Class Actions for Non-Class-action lawyers. Growing Your Business by Understanding the Basics and Recognizing Opportunities,” Los Angeles, CA, February 21, 2008, sponsored by the Los Angeles County Bar Association

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Panelist, “Class Action Removal Standards in Flux. New Litigation Strategies for Plaintiff and Defense Counsel,” National Teleseminar, February 19, 2008, sponsored by Strafford Publications

Panelist and Moderator, ABA’s 11th Annual National Institute on Class Actions, “The Nationwide Class: White Elephant, Endangered Species, or Alive and Well?” Chicago, IL, October 19, 2007, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Panel Co–Chair, ABA’s 2007 Annual Meeting, “‘Is this CAFA or Kafka?’ Multi–State Class Actions in a Time of Metamorphosis—A Surreal-Life, Three-Act Play,” San Francisco, CA, August 9–12, 2007, sponsored by the ABA

Panelist, ABA’s 2007 Litigation Section Annual Conference, “The Last Laugh-Perspectives on CAFA,” San Antonio, TX, April 11–14, 2007, sponsored by the ABA Lecturer, “Class Actions for Non–Class-action lawyers,” Los Angeles, CA, February 23, 2007, sponsored by the Los Angeles County Bar Association

Moderator, ABA’s 10th Annual National Institute on Class Actions, Chicago, IL, October 27, 2006, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Lecturer, “The Business Litigation Seminar,” Cleveland, OH, June 21, 2006, sponsored by the Cleveland Bar Association

Featured Speaker, “Price Fixing and Market Allocation Schemes in the Commodity Chemicals Business—How to Avoid Being a Victim,” Cleveland, OH, June 16, 2006, sponsored by the Cleveland Chemical Association

Lecturer, “Class Actions: Growing Your Business by Understanding the Basics and Recognizing Opportunities,” Cleveland, OH, June 6, 2006, sponsored by the Cleveland Bar Association Lecturer/Panelist, “Civil Practice and Litigation Techniques in Federal and State Courts,” Charleston, SC, May 31, 2006, sponsored by ALI-ABA

Lecturer, “Class Actions for Non–Class-action lawyers,” Los Angeles, CA, February 25, 2006, sponsored by the Los Angeles County Bar Association

Lecturer, “Class Actions: Growing Your Business by Understanding the Basics and Recognizing Opportunities,” Cleveland, OH, December 6, 2005, sponsored by the Cleveland Bar Association

Lecturer, “Class Actions: Growing Your Business by Understanding the Basics and Recognizing Opportunities,” Cleveland, OH, November 18, 2005, sponsored by the Cuyahoga County Bar Association

Featured Speaker, “Price Fixing and Market Allocation Schemes in the Commodity Chemicals Business-How to Avoid Being a Victim,” Pittsburgh, PA, November 11, 2005, sponsored by the Pittsburgh Chemical Association

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Moderator, “ABA’s 9th Annual National Institute on Class Actions,” Chicago, IL, September 23, 2005, sponsored by the ABA’s Litigation Section’s Class Action and Derivative Suits Committee

Featured Speaker, “Price Fixing and Market Allocation Schemes in the Commodity Chemicals Business-How to Avoid Being a Victim,” Cleveland, OH, September 16, 2005, sponsored by the Cleveland Chemical Association

Featured Speaker, “Price Fixing and Market Allocation Schemes in the Commodity Chemicals Business–How to Avoid Being a Victim,” Vail, CO, July 26, 2005, sponsored by the OC Chemical Dealers’ Association

Lecturer, “Class Actions: Growing Your Business by Understanding the Basics and Recognizing Opportunities,” Cleveland, OH, May 20, 2005, sponsored by the Cleveland Bar Association

Lecturer, “Class Actions for Non-Class-action lawyers,” Miami, FL, May 13, 2005, sponsored by Lighthouse Seminar Group, Dallas, TX

Lecturer, “Class Actions for Non-Class-action lawyers: Understanding the Basics and Recognizing Opportunities,” Phoenix, AZ, March 25, 2005, sponsored by the Maricopa County Bar Association

Lecturer, “Class Actions for Non-Class-action lawyers,” Chicago, IL, January 21, 2005, sponsored by Lighthouse Seminar Group, Dallas, TX

Lecturer, “Recognizing Class Action Opportunities,” Columbus, OH, December 12, 2004, sponsored by the Columbus Bar Association

Lecturer, “Class Actions: Understanding the Basics and Recognizing Opportunities,” Cleveland, OH, May 28, 2004, sponsored by the Cleveland Bar Association

Lecturer, “Select Topics for Trial Lawyers, A Primer on Class Actions for the Non–Class Action Litigator in New York,” New York, NY, August 11, 2004, sponsored by Lorman Educational Services, Eau Claire, WI

Lecturer, “The Business Litigation Seminar—Advanced Tactics and Motions,” Cleveland, OH, December 12, 2003, sponsored by the Cleveland Bar Association

Lecturer, “Community Litigation Workshop,” Detroit, MI, June 5, 1998, sponsored by the Firearms Litigation Clearinghouse, Washington D.C.

14 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 130 of 253 PageID# 11553

PROFESSIONAL ACTIVITIES

American Bar Association, 2003–Present Chairperson, National Institute on Class Actions, 2010–Present Litigation Section, Co-Chair, Class Action and Derivative Suits Committee’s Antitrust Subcommittee, 2007–2008 Antitrust Section, 2008–2010

Host, Your Lovable Lawyer, www.yourlovablelawyer.com, 2020–Present Contributor, A. Scalia & B. Garner, Reading Law: The Interpretation of Legal Texts (2012)

Law360, Columnist, 2017–Present

American Society of Writers on Legal Subjects, 2004–Present Law Review Award Committee, 2004–2009 Brief-Writing Committee, 2004–2009

American Association for Justice, 1998–Present Co-Chair, Class Action Litigation Group, 2018–2020 Co-Vice Chair, Class Action Litigation Group, 2016–2018 Secretary, Class Action Litigation Group, 2015–2016 Litigation Group Leaders Council, 2018–Present Co-Chair, Antitrust Subcommittee, 2016–Present Vice Co–Chair, Antitrust Subcommittee, 2015–2016 ABA Liaison Committee, 2014–Present Rule 23 Subcommittee, 2014–Present

Loyola Chicago Consumer Law Review Advisory Board, 2018–Present

The William K. Thomas American Inn of Court—American Inns of Court, 2018–Present

Class Action Trial Lawyers’ Association, 2011–Present Executive Committee, 2011–Present

Cleveland Bar Association, 1997–2009

National Association for Consumer Advocates, 2003–2013

BOARD MEMBERSHIPS AND CIVIC ACTIVITIES

Ohio Association for Justice, 2003–Present Board of Trustees, 2012–2016 Chair, Consumer Law Section, 2014–2016

Cleveland Metropolitan Bar Association, Multidistrict Litigation Task Force, 2010–2012

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Consumer-law correspondent, Your Legal Minute with the Lovable Lawyer, The Weekly Pulse, WKYC-Cleveland, 2018–2019

Loyola University Chicago School of Law, Institute for Consumer Antitrust Studies’ U.S. Advisory Board, 2004–Present IUvisors Student Advisors, Indiana University Alumni Foundation, 2014–Present

Student Mentor, Loyola Consumer Antitrust Institute’s Mentoring Program, Loyola University Chicago School of Law, 2018–Present

Antitrust Section Council Member, Ohio State Bar Association, 2007–Present Great Lakes Antitrust Institute Planning Committee, 2013 Cleveland Legal Aid Society Volunteer Attorney, 2014–2016

Public Justice, 2011–Present

Editorial Board, Ohio Academy of Trial Lawyers’ Ohio Trial Magazine, 2004–2010

Class Action Advisory Board, Strafford Legal Publications, 2008–Present

Editorial Board, American Bar Association, Litigation Section’s Class Actions Today. Jurisdiction to Resolution (special publication), 2007–2008

Assistant Coach, Northern Ohio Warriors Traveling Youth Baseball Club, 2014–2016

Fellow, Litigation Counsel of America Trial Lawyer Honorary Society, 2008–2010

Women’s Community Foundation, Men’s Executive Committee, 2004–2010

Judge, Landskroner Foundation for Children’s 9th Annual Law Student Closing Argument Competition, 2007

Anti-Defamation League’s Steinberg Leadership Institute, 1998–2000

Associate Attorney’s Committee Co-Chair, Lawyers’ Division, Jewish Federation of Metropolitan Chicago, 1995–1997

DePaul University College of Law, Moot Court Judge, 1993–1994

Sigma Alpha Mu, Sigma Zeta Housing Corporation, 2004–2009

Young Leadership Board, Jewish Federation of Metropolitan Chicago, 1993–1997

Young Leadership Board, Jewish Community Federation of Cleveland, 1997–2000

16 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 132 of 253 PageID# 11555

MEDIA APPEARANCES

WKYC NBC3, “George Clooney to produce docuseries on Ohio State sexual abuse scandal,” Feb. 22, 2021

WKYC NBC3, “COVID-Q9 vaccine: Your legal questions answered,” Dec. 15, 2020

WKYC NBC3, “Exclusive: OSU sex abuse survivors say ‘gender bias’ is stalling settlement talks,” Oct. 13, 2020

Law360, “6 Law Firms Vie To Head FirstEnergy Shareholder Suit,” Sept. 29, 2020

Top Class Actions, “Tyson Class Action Lawsuit Says Beef Prices are Inflated,” Sept. 17, 2020

Law360, “Investor Claims Ohio Utility Played Role In $60M Bribery Plot,” Aug. 21, 2020

WKYC NBC3, “Evenflo accused of defective car seats,” August 5, 2020 Law360, OSU Says Sex Assault Claims Against Doctor Are Too Old, July 8, 2020

Fair Cattle Markets, Interview with Daniel Karon, Attorney representing Central Grocers, June 23, 2020

The Fence Post, “Grocers File Lawsuit Against Meatpackers for Violating the Sherman Act,” June 15, 2020

Tri-State Livestock News, “Lawsuit Number 3,” June 12, 2020

Law360, Hottest Legal Industry Guest Topics Of 2019, December 23, 2019

Beef Magazine, “Class action lawsuit filed against beef packers,” June 11, 2020

Feedstuffs, “Class action lawsuit filed against beef packers,” June 9, 2020

Bloomberg Law, “Cargill, JBS, Top Meatpackers Accused of Driving Up Prices,” June 8, 2020

WKYC NBC3, “What are Workers’ Rights During the Coronavirus Outbreak?” March 26, 2020

WEWS NewsChannel 5, “Corona Virus: How You Can Still Plan for Big Events,” March 14, 2020

Law360, OSU Reaches Settlement With Some Sex Abuse Accusers, May 6, 2020

Law360, OSU Not Handling Sex Abuse Talks In Good Faith, Judge Told, February 25, 2020

WOIO CBS 19News, “Myles Garrett in the News,” November 15, 2019

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WOIO CBS 19News, More Than 100 Former OSU Students Come Forward with Allegations of Sexual Misconduct by Team Doctor, July 21, 2019

WOIO CBS 19News, “Ohio State Sex Abuse Interview,” May 20, 2019

WEWS NewsChannel 5, “Ohio State Sex Abuse Interview,” May 20, 2019

Fox News 8 Cleveland, “Cleveland Attorney Represents Alleged Victim, Fights for Justice in OSU Sexual Abuse Case,” May 18, 2019

Fox News 8 Cleveland—Live Facebook feed, “Cleveland Attorney Represents Alleged Victim, Fights for Justice in OSU Sexual Abuse Case,” May 18, 2019

Cleveland Jewish News, “OSU Investigation: Doctor Strauss Abused at Least 177 Students,” May 17, 2019

Columbus Jewish News, “OSU Investigation: Doctor Strauss Abused at Least 177 Students,” May 17, 2019

All Rise—the Ohio State University Moritz College of Law, Alumni Profile, Winter 2019

Cleveland.com, “State’s high court says customers must show damages in class action case,” Jan. 11, 2019

Law360, “New Deposition Rule Could Have Benefits but Lawyers Hate It,” February 25, 2019

WKYC NBC3 Cleveland, “Cleveland Attorney Represents Alleged Victim, Fights for Justice in OSU Sexual Abuse Case,” July 18, 2018

The Lantern, “Ohio State Faces Second Class Action Lawsuit Pertaining to Doctor’s Sexual Abuse,” July 17, 2018

The Daily Record, Ex-Wrestlers Sue Ohio State, Say Officials Knew of Doctor’s Sexual Abuse,” July 17, 2018

The Columbus Dispatch, Ex-Wrestlers Sue Ohio State, Say Officials Knew of Doctor’s Sexual Abuse,” July 17, 2018

Side Bar: the Moritz Newsletter, Expose, October 30, 2017

Bloomberg BNA, “Posner: Class Action Rules, Constitution Overrated,” October 28, 2016

Cleveland Plain Dealer, “Ruling May Make Class-Action Suits Harder to Mount,” September 9, 2015

21WFMJ, Warren woman files $5,000,000 suit against hospital operator over data breach, Mar. 6, 2015,

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Cleveland.com, State’s high court says customers must show damage in class action case, September 5, 2015

Law360, “BASF, Others Face Price-Fixing Suit for Polyurethane Input,” July 9, 2013

Cleveland Plain Dealer, “Grove City Truck Firm is Latest to Sue Pilot Flying J,” June 1, 2013

Madison Record, “ABA—Panel Discusses Class Action Lawsuits and their Bad Reputation, August 6, 2012

Cleveland Plain Dealer, “Take Me Out to a Ballpark—Midday Makeup Game Draws Determined Crowd,” September 21, 2011

Lawyers and Settlements, Featured Case, March 22, 2010

ABA Journal, “A Step Up in Class,” May 1, 2008

Miami Herald, “Banana Battle Heads to Court,” September 2, 2005

National Law Journal, “Antitrust Dilemma Emerges in U.S. Courts,” September 19, 2005

Cleveland.com, State’s high court says customers must show damages in class action case, September 8, 2015

RDS Business and Management Practices, “Banana Battle Heads to Court,” September 1, 2005

The Palm Beach Daily Business Review, Kimball on Real Estate, March 24, 2015

St. Paul Pioneer Press, “Assault on a System,” March 14, 2004

PODCASTS

Our Curious Amalgam, sponsored by the American Bar Association, Mar. 29. 2021

HONORS AND AWARDS

Norvelle Scholarship for Academic Excellence, Indiana University, 1986

Ohio Super Lawyer, 2012–Present

Global Directory of Who’s Who (Top Lawyer), 2015–Present

ABA Center for Professional Development Partner Appreciation Award Winner for Most Innovative Presentation, 2015

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ABA Award for Outstanding Subcommittee Chair for the Class Actions & Derivative Suits Committee 2010–2011

Top Attorneys of North America, 2017–Present

Best Lawyers in America, Mass Tort Litigation/Class Actions—Plaintiffs, 2018–Present Martindale-Hubbell AV Preeminent® Peer-Review Rating (reflecting combination of very high general ethical standards and legal ability and measuring legal knowledge, analytical capabilities, judgment, communication ability, and legal experience), 2012–Present

AcademicKeys Who’s Who in Law Higher Education, 2017–Present US News Best Lawyers–Best Law Firms, 2019–Present

Best Lawyers Business Edition—The Litigation Issue 2019 Best Consumer Law & Antitrust Law Firm 2019—Ohio Leading Legal Mind in Class Action Lawsuits (Ohio)

America’s Top 100 High Stakes Litigators, 2020

America’s Most Honored Lawyers, The American Registry, 2020

Beau D. Hollowell

EDUCATION

J.D., 2006 Case Western Reserve University School of Law Dean’s List Paul J. Hergenroeder Award for Trial Tactics CALI Award (highest grade) for Trial Tactics

B.A., English, 2002 Westminster College Dean’s List

BAR ADMISSIONS

Ohio, 2006

Illinois (inactive), 2009

United States Court of Appeals for the Sixth Circuit, 2007

United States District Court for the Northern District of Ohio, 2008

United States District Court for the Southern District of Ohio, 2011 20 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 136 of 253 PageID# 11559

LITIGATION EXPERIENCE

Karon LLC, Cleveland, OH Attorney, 2014–Present

Marshall Dennehey Warner Coleman & Goggin, Cleveland, OH Attorney, 2010–2014

Sarles & Ouimet, LLC, Chicago, IL Attorney, 2008–2010

21 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 137 of 253 PageID# 11560

Reminger & Reminger, Co., LPA, Cleveland, OH Attorney, 2006–2008 Law Clerk, 2004–2006

22 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 138 of 253 PageID# 11561

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Karon LLC Reporting Period: Inception through February 28, 2021

Historical Name Status Total Hours Hourly Rate Total Lodestar Karon, Daniel P 23.50 $840.00 $19,740.00

TOTALS 23.50 $19,740.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 139 of 253 PageID# 11562

Exhibit A-20 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 140 of 253 PageID# 11563

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF E. POWELL MILLER IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN AWARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, E. Powell Miller, hereby declare as follows:

1. I am a Partner at the law firm of The Miller Law Firm, P.C .. I submit this declaration

m support of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees,

Reimbursement of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of the The Miller Law Firm, P.C. and

its attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. The

hourly rates for my firm's attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm in antitrust class actions. This includes work performed by my

firm's attorneys and professional staff, computed at my firm's historical hourly rates, through

February 28, 2021. Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 141 of 253 PageID# 11564

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 194.2 hours. The total lodestar for my firm is $87,227.50. My firm's lodestar amount

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm's attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm's contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm's lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $35,068.36 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $35,000 in

contributions to the Indirect Purchaser Plaintiffs' joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses through March 31, 2021, in accordance with the guidelines

established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

2 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 142 of 253 PageID# 11565

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 29th day of April 2021 in Rochester, Michigan.

(!' -f]H/{J_~ E. Powell Miller (P3,9487) THE MILLER LAW FIRM, P .C. 950 West University Dr., Ste. 300 Rochester, MI 48307 (248) 841-2200 (248) 652-2852 fax [email protected]

3 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 143 of 253 PageID# 11566

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 144 of 253 PageID# 11567

THE MILLER LAW FIRM

A Professional Corporation

950 W. University Dr., Ste. 300 Rochester, MI 48307 (248) 841-2200

www.millerlawpc.com

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 145 of 253 PageID# 11568

THE MILLER LAW FIRM, p .c. I FIRM RESUME

The Miller Law Firm, P.C. (the “Firm”) is one of the premier litigation law firms in the United States and Michigan’s leading financial class action firm. A recognized leader in the area of complex commercial litigation, the Firm is ranked Tier 1 in Detroit by U.S. News- Best Lawyers “Best Law Firms” for commercial litigation. Since the Firm’s founding in 1994, the Firm has developed a national reputation for successfully prosecuting securities fraud and consumer class actions on behalf of its clients. As Lead Counsel or Co-Lead Counsel appointed by judges throughout the United States in some of the country’s largest and most complex cases, the Firm has achieved over $1 billion in settlements and/or verdicts on behalf of injured class members.

Highlights of Results Obtained

2019 Carl Palazzolo, et al. Fiat Chrysler Automobiles N.V., et al. (United States District Court, Eastern District of Michigan) (Case No. 16-cv-12803) (Co-Lead Counsel)

Result: $14,750,000

Zimmerman v. Diplomat Pharmacy, Inc., et al. (United States District Court, Eastern District of Michigan) (Case No. 2:16-cv-14005) (Liaison Counsel)

Result: $14,100,000

2018 In re Freight Forwarders Antitrust Litigation (United States District Court, Eastern District of New York) (Case No. 08-cv-00042) (Counsel for Class Representative)

Result: $1 billion settlement amount

2017 Foster v. L3 Communications, EO Tech (United States District Court, Western District of Missouri) (Case No. 15-cv-03519) (Co-Lead Counsel)

Result: $51 million (100% recovery)

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 146 of 253 PageID# 11569

2016 In re Automotive Parts Antitrust Litigation (United States District Court, Eastern District of Michigan) (Case No. 12-md-02311) (Liaison Counsel)

Result: Over $1 billion in settlements

GM Securities Class Action/New York Teachers Retirement System v. General Motors Company (United States District Court, Eastern District of Michigan) (Case No. 4:14-cv-11191) (Local Counsel)

Result: $300 million settlement

ERISA Class Action/Davidson v. Henkel Corporation (United Sates District Court, Eastern District of Michigan) (Case No. 12-cv-14103) (Lead Counsel)

Result: $3.35 million settlement (100% Recovery for 41 member class)

Pat Cason-Merenda and Jeffrey A. Suhre v. VHS of Michigan, Inc., dba Detroit Medical Center (Antitrust) (United States District Court, Eastern District of Michigan) (Case No. 2:06-cv-15601) (Special Trial Counsel)

Result: $42 million settlement

2015 In re AIG 2008 Securities Litigation (United States District Court, Southern District of New York) (Case No. 08-cv-04772) (Co-Lead Counsel)

Result: $970.5 million settlement

City of Farmington Hills Employees Retirement System v. Wells Fargo Bank, N.A. (United States District Court, District of Minnesota) (Case No. 10-cv-04372) (Co-Lead Counsel)

Result: $62.5 million settlement approved

2014 City of Farmington Hills Employees Retirement System v. Wells Fargo Bank, N.A. (United States District Court, District of Minnesota) (Case No. 10-cv-04372) (Co-Lead Counsel and Primary trial counsel)

Result: $62.5 million settlement approved

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 147 of 253 PageID# 11570

The Shane Group, Inc., et al. v. Blue Cross Blue Shield of Michigan (United States District Court, Eastern District of Michigan) (Case No. 2:10-cv-14360) (Interim Co-Lead)

Result: $30 million settlement pending final approval

In re Refrigerant Compressors Antitrust Litigation (United States District Court, Eastern District of Michigan) (Case No. 09-md-02042) (Interim Co-Lead)

Result: $30,000,000 settlement

2013 The Board of Trustees of the City of Birmingham Employees et. al. v. Comerica Bank et. al. (United States District Court, Eastern District of Michigan) (Case No. 2:09-13201) (Co-Lead Counsel)

Result: $11,000,000 settlement

In Re Caraco Pharmaceutical Laboratories, Ltd. Securities Litigation (United States District Court, Eastern District of Michigan) (Case No. 2:09-cv-12830) (Co-Lead Counsel for the Class)

Result: $2,975,000 settlement

In Re TechTeam Global Inc. Shareholder Litigation (Oakland County Circuit Court, State of Michigan) (Case No. 10-114863-CB) (Liaison Counsel)

Result: $1,775,000 settlement

General Retirement System of the City of Detroit and Police and Fire Retirement System of the City of Detroit vs. UBS Securities, LLC (Structured Investment Vehicle) (United States District Court, Eastern District of Michigan) (Case No. 2:10-cv-13920) (Lead Counsel)

Result: Confidential settlement

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 148 of 253 PageID# 11571

2010 Epstein, et al v. Heartland Industrial Partners, L.P., et al (United States District Court, Eastern District of Michigan) (Case No. 2:06-CV-13555) (Substantial role)

Result: $12,262,500 settlement

In Re Skilled Healthcare Group, Inc. Securities Litigation (United States District Court, Central District of California) (Case No. 09-5416) (Substantial role)

Result: $3,000,000 settlement

2009 In Re Proquest Company Securities Litigation (United States District Court, Eastern District of Michigan) (Case No. 4:06-CV-11579) (Substantial role; argued Motion to Dismiss)

Result: $20,000,000 settlement

In Re Collins & Aikman Corporation Securities Litigation (United States District Court, Eastern District Michigan) (Case No. 03-CV-71173) (Substantial role)

Result: $10,800,000 settlement

In re IT Group Securities Litigation (United States District Court, Western District of Pennsylvania) (Civil Action No. 03-288) (Co-Lead)

Result: $3,400,000 settlement

2008 In re Mercury Interactive Securities Litigation (United States District Court, Northern District of California) (Civil Action No. 03:05-CV-3395-JF) (Substantial role)

Result: $117,000,000 settlement

In Re General Motors Corporation Securities and Derivative Litigation (United States District Court, Eastern District of Michigan) (Master Case No. 06-MD-1749) (Co-Lead)

Status: Obtained major corporate governance reforms to address accounting deficiencies Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 149 of 253 PageID# 11572

2007 Wong v T-Mobile USA, Inc. (United States District Court, Eastern District of Michigan) (Case No. 05-CV-73922) (Co-Lead)

Result: Settlement for 100% of damages.

In re CMS Energy Corporation Securities Litigation (United States District Court, Eastern District Michigan) (Master File No. 2:02 CV 72004) (Substantial role)

Result: $200,000,000 settlement

2005 In re Comerica Securities Fraud Litigation (United States District Court, Eastern District of Michigan) (Case No. 2:02-CV-60233) (Substantial role)

Result: $21,000,000, divided between related cases at $15,000,000 and $6,000,000

2005 Street v Siemens (Philadelphia State Court) (Case No. 03-885) (Co-Lead)

Result: $14,400,000, including 100% recovery for more than 1,000 workers wrongfully deprived of pay.

2005 Redmer v Tournament Players Club of Michigan (Wayne County Circuit Court) (Case No. 02-224481-CK) (Co-Lead)

Result: $3,100,000 settlement

2004 Passucci v Airtouch Communications, Inc. (Wayne County Circuit Court) (Case No. 01-131048-CP) (Co-Lead)

Result: Estimated settlement valued between: $30,900,000 to $40,300,000.

Johnson v National Western Life Insurance (Oakland County Circuit Court) (Case No. 01-032012-CP) (Substantial role)

Result: $10,700,000 settlement on behalf of nation-wide class of purchasers of annuities. Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 150 of 253 PageID# 11573

2003 Felts v Starlight (United States District Court, Eastern District Michigan) (Case No. 01-71539) (Co-Lead)

Result: Starlight agrees to stop selling ephedrine as an ingredient in its weight loss dietary supplement product.

In re Lason Securities Litigation (United States District Court, Eastern District Michigan) (Case No. 99-CV-76079) (Co-Lead)

Result: $12,680,000 settlement

2001 Mario Gasperoni, et al v Metabolife International, Inc. (United States District Court, Eastern District Michigan) (Case No. 00-71255) (Co-Lead)

Result: Nationwide settlement approved mandating changes in advertising and labeling on millions of bottles of dietary supplement, plus approximately $8,500,000 in benefits.

1999 Pop v Art Van Furniture and Alexander Hamilton Insurance Company (Wayne County Circuit Court)(Case No. 97-722003-CP) (Co-Lead)

Result: Changes in sales practices and $9,000,000 in merchandise.

Schroff v Bombardier (United States District Court, Eastern District Michigan) (Case No. 99-70327) (Co-Lead)

Result: Recall of more than 20,000 defective Seadoos throughout North America; repair of defect to reduce water ingestion problem; extended warranties; and approximately $4,000,000 in merchandise.

In re National Techteam Securities Litigation (United States District Court, Eastern District Michigan) (Master File No. 97-74587) (Substantial role)

Result: $11,000,000 settlement

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 151 of 253 PageID# 11574

In Re F&M Distributors, Inc., Securities Litigation (United States District Court, Eastern District Michigan) (Case No. 95-CV-71778-DT) (Minor role)

Result: $20,000,000 settlement

1998 In Re Michigan National Corporation Securities Litigation (United States District Court, Eastern District Michigan) (Case No 95 CV 70647 DT) (Substantial role)

Result: $13,300,000 settlement

1995 In re Intel Pentium Processor Litigation (Superior Court, Santa Clara County, California)(Master File No. 745729) (Substantial role)

Result: Intel agreed to replace millions of defective Pentium chips on demand without any cost to consumers. Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 152 of 253 PageID# 11575

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust

Firm Name: The Miller Law Firm, P.C. Reporting Period: Inception through February 28, 2021

Historical Hourly Total Name Status Total Hours Rate Lodestar Miller, E Powell P 6.10 $890.00 $5,429.00 O'Shea Kevin P 1.00 $825.00 $825.00 Allard, Devon P 69.80 $695.00 $48,511.00 McNair, Lee A 88.70 $285.00 $25,279.50 Smith, Monica A 19.50 $285.00 $5,557.50 Sia, Melissa A 0.30 $285.00 $85.50 Dumar, Christi PL 8.80 $175.00 $1,540.00

TOTALS 194.2 $87,227.50

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 153 of 253 PageID# 11576

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: The Miller Law Firm, P.C. Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research Filing / Misc. Fees Overnight Delivery/Messengers Photocopying $13.00 Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $55.36 Litigation Fund Contributions $35,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $35,068.36 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 154 of 253 PageID# 11577

Exhibit A-21 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 155 of 253 PageID# 11578

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3: 18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF SHARP LAW LLP IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS' MOTION FOR AN A WARD OF ATTORNEYS' FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE A WARDS TO THE CLASS REPRESENTATIVES

I, Isaac Diel, hereby declare as follows:

1. I am a partner at the law firm of Sharp Law LLP. I submit this declaration in support

of Indirect Purchaser Plaintiffs' Motion for an Award of Attorneys' Fees, Reimbursement of

Expenses, and Service A wards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Sharp Law LLP and its attorneys

are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm's total hours and attorneys'

fee lodestar in this litigation for work performed at the direction oflnterim Co-Lead Counsel. This

includes work performed by my firm's attorneys and professional staff, computed at my firm's

historical hourly rates, for the period through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 78.9. The total lodestar for my firm is $50,465.00. My firm's lodestar amount includes

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only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm's attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm's contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm's lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $10,094.84 in

unreimbursed costs and expenses in this litigation during the period from December 26, 2018

through March 31, 2021, including $10,000 in contributions to the Indirect Purchaser Plaintiffs'

joint litigation fund. My firm advanced these costs and expenses with no assurance that such costs

and expenses would be repaid. My firm has only set forth costs and expenses incurred through

March 31, 2021, in accordance with the guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

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Executed this 28th day of April 2021 in Overland Park, Kansas.

Isaac Diel

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EXHIBIT A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 159 of 253 PageID# 11582

Law Firm Resume of Sharp Law LLP www.SharpLawLLP.com

The attorneys at Sharp Law LLP have extensive experience handling class actions in state and federal courts throughout the United States. Combined, the lawyers in the firm are licensed to practice in five states and have appeared in dozens of state and federal courts from coast to coast. Rex Sharp is one of the region's most respected litigation attorneys and has served as lead counsel in over 50 class actions. Two other lawyers in the firm have served as law clerks for two federal judges and one state supreme court justice. The law firm Sharp Law LLP was formed in January 2020 to continue serving the litigation needs of small businesses and individuals in the Midwest region after the dissolution of Rex A. Sharp, P.A., which had been formed in 2004. Primarily focused on pursuing class actions for individual and small business plaintiffs, the firm has a national footprint developed over decades of successfully handling complex cases in state and federal courtrooms across the United States. The firm's attorneys started their careers at major law firms in Houston, San Francisco, and Dallas, and today they regularly pursue and win cases against many of the world's most sophisticated Fortune 500 defendants and national defense law firms.

REX A. SHARP. Position: President of Sharp Law LLP. Born Liberal, Kansas, 1960; admitted to bar, 1985, Texas, Kansas and U.S. District Court, District of Kansas; 1986, Oklahoma and U.S. District Court, Southern District of Texas; 1987, U.S. District Court, Northern District of Texas and U.S. District Court, Western District of Oklahoma; 1988, Colorado; 1988, U.S. Court of Appeals, Tenth Circuit; 1990, U.S. Supreme Court; 1998, U.S. District Court, Northern District of Oklahoma and U.S. District Court, Western District of Missouri; 2000 Missouri; 2004, U.S. Court of Appeals, Fifth Circuit; 2006, U.S. Court of Appeals, Eighth Circuit, 2009, U.S. Court of Appeals, Seventh Circuit; 2011, U.S. District Court, Eastern District of Oklahoma; 2014, U.S. District Court, District of Colorado. Education: University of Oklahoma; Stanford University (A.B., with honors and distinction, 1982); University of Michigan (J.D., cum laude, 1985). Phi Beta Sigma. Campbell Moot Court Finalist. Recipient, S. Anthony Benton Best Brief Awards. Author: Note, "The Admissibility of Prior Silence to Impeach the Testimony of Criminal Defendants," 18 University of Michigan Journal of Law Reform 741-66, 1985; Sharp, "Paying for the Crimes of Others? Landowner Liability for Crimes on the Premises," 29 South Texas Law Review 11-81, 1987; ABA Annual Survey of State Class Action Law, Kansas 2007-2014. Assistant City Attorney and City Attorney, Liberal, Kansas 1988-97. Member, Kansas Board for Discipline of Attorneys (1996-2015); Kansas, Missouri, Oklahoma, Colorado and American Bar Associations; State Bar of Texas. Board Certified Civil Trial Advocacy Specialist by the National Board of Trial Advocacy; Super Lawyer (2008-present). Practice Areas: Civil Litigation; Class Actions; Oil and Gas; Municipal Law. E-mail: [email protected] Martindale Hubbell rating "AV".

BARBARA C. FRANKLAND. Born: Philadelphia, Pennsylvania, 1964; admitted to bar 1989, Kansas and U.S. District Court, District of Kansas; 1990, California, and U.S. District Court, District of Northern California; 1994, Missouri, and U.S. District Court, Western District of Missouri; U.S. Court of Appeals, Eighth and Tenth Circuits; 2014, United States Supreme Court; 2015, U.S. District Court of Colorado; 2017, Oklahoma and

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U.S. District Courts, Eastern District of Oklahoma, Northern District of Oklahoma, and Western District of Oklahoma. Education: Cornell University, B.A., 1986; University of Kansas School of Law, J.D., 1989. American Jurisprudence Award in Alternative Dispute Resolution, 1989; Chairman, The Central Exchange, 2000-2001; Award recipient for Ingram's Magazine 40 Under 40, Class of2000; Recipient of the Kansas City Scout Award Charter Class for the Native Sons of Greater Kansas City, 2001; Officer, March of Dimes Board, Greater Kansas City Division, 2001-2002. ABA Annual Survey of State Class Action Law, Kansas 2015-2017. Kansas, Missouri, Oklahoma, and California Bar Associations. Practice Areas: Class Actions; Civil Litigation; Oil and Gas. E-mail: bfran.kland(@,midwest-law.com Martindale Hubbell rating "BV".

GREGORY M. BENTZ. For over 30 years Greg Bentz has advised and advocated for our clients. He is equally at home in both the courtroom and the boardroom. Greg has a strong substantive knowledge of the antitrust laws and all types of business disputes. His understanding of legal, business, and financial principles allows him to efficiently assist clients in reaching their business objectives. Named "Lawyer of the Year" by Best Lawyers® for Litigation-Antitrust Law in Kansas City, MO, 2020; Selected for inclusion in The Best Lawyers in America® in the fields of: Commercial Litigation (2012-2020), Litigation-Antitrust (2012-2020); Named "Best of the Bar - Business Litigation" by Kansas City Business Journal; Selected for inclusion in Missouri & Kansas Super Lawyers, 2011-2019; Recipient of KCMBA President's Award for Outstanding Service, 2010; Recipient of Kansas City Metropolitan Bar Foundation President's Award for Outstanding Service, 2004.

ISAAC (IKE) L. DIEL. Graduated from Emporia State University (B.S., 1986) and was a member of the varsity football team achieving Academic All American honors during the 1985 season. He subsequently graduated from the University of Oklahoma School of Law (J.D., with distinction, 1989). While in law school, Mr. Diel was the Assistant Managing Editor for the American Indian Law Review. He was admitted to practice in the state and federal courts of Missouri in 1989, the state and federal courts of Kansas in 1990, and the Tenth Circuit Court of Appeals in 2005. Mr. Diel is a member of the Kansas Bar Association and the American Bar Association (member, Antitrust Section). He is also a member of the Board of Trustees for the Emporia State University Foundation.

RYAN C. HUDSON. Born: Pittsburg, KS, 1979. Admitted to bar 2005, Missouri; Texas, 2006; Kansas, 2008; and U.S. District of the District of Kansas, 2010; U.S. District Court for the Western District of Missouri, 2010; U.S. District Court for the Northern District of Texas, 2006, and Eastern District of Texas, 2008; U.S. Court of Appeals for the Federal Circuit, 2009; and U.S. Court of Appeals for the Tenth Circuit, 2014; 2017, Oklahoma and U.S. District Courts, Eastern District of Oklahoma, Northern District of Oklahoma, and Western District of Oklahoma. Education: University of Kansas, B.A., 2001 (With Honors and Highest Distinction; Phi Beta Kappa); University of Kansas School of Law, J.D., 2005 (Order of the Coif; Member of Kansas Law Review; Moot court competition co champion). Clerkship Experience: Law Clerk to the Honorable John W. Lungstrum, U.S. District Court for the District of Kansas (2005-06). Recognized as "Best of the Bar" by the Kansas City Business Journal; recognized as a Kansas & Missouri "Rising Star" in Business Litigation by Kansas City Magazine; recognized as a Texas "Rising Star" in

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Litigation by Texas Monthly; elected a Fellow of the Dallas Association of Young Lawyers; University of Kansas Law School, Moot Court Alumni Council. Practice Areas: class actions; business disputes; intellectual property; oil, gas, & energy securities litigation and fraud; and federal criminal defense. Class action experience: has served as co-lead counsel in class cases and has led class actions that have generated millions of dollars for consumers and individuals across the country. Email: [email protected]

LARKIN WALSH. Born: Kansas City, Missouri, 1979. Admitted to bar 2004, Kansas; 2005, Missouri; 2004, U.S. District Court for the District of Kansas; 2016, U.S. Court of Appeals-Fourth Circuit; 2017, U.S. Court of Appeals-Tenth Circuit. Education: Southern Methodist University, BA, BFA, 2001; University of Kansas School of Law, J.D., 2004. Clerkship experience: Law Clerk to the Honorable Carlos Murgia, U.S. District Court for the District of Kansas. Research attorney for Justice Carol Beier, Kansas Supreme Court. Appointed by the Kansas Supreme Court to serve on the Board of Law Examiners. Co-chair of the Kansas Bar Association's Annual Survey of Law.

SCOTT B. GOODGER. Born Kansas City, Missouri, 1988; admitted to bar 2014, Kansas; 2016, Missouri; 2017, Texas; U.S. District Court for the District of Kansas, 2014. Education: Trinity University, B.A. 2011; University of Kansas School of Law, J.D., 2014 (Member of the Kansas Law Review).

ALLISON B. WATERS. A seventh generation Texan who traces her ancestry to the Republic of Texas, Allison is now proud to call herself a Kansan. She has practiced complex class action and commercial litigation for over 23 years, with extensive trial experience in state and federal courts in Texas and Oklahoma and before arbitration tribunals. Her practice is focused is on oil and gas royalty disputes, securities fraud, and employment matters. She is published in the South Texas Law Review and, while in law school, served as Assistant Editor-in-Chief of the STCL Law Review. Allison also has a passion for representation of children, providing pro bono assistance in adoption cases and advocacy on behalf of special needs families. She volunteers her time extensively in support of local non-profit organizations focused on child advocacy.

SARAH TANKARD BRADSHAW. Born Kansas City, MO, 1986; admitted to bar in Missouri, 2013; U.S. District Court for the Western District of Missouri, 2016; U.S. District Court for the District of Kansas, 2018; U.S. District Court for the District of Colorado, 2018; Kansas, 2019. Education: University of Kansas, B.A., 2009; University ofMissouri Kansas City, J.D., 2013.

GREGORY WRIGHT. Graduated from the University of Kansas Law school in 1997, a member of the Kansas Law Review and recipient of the W. Ross Hutton Award. He represents individuals and businesses in state and federal courts throughout the country. His practice focuses on complex class actions and commercial litigation, with emphasis in the areas of antitrust, consumer protection, oil & gas royalty rights, shareholder derivative actions, merger litigation, and business and commercial disputes. Greg has been appointed class counsel in several class action cases and played leadership roles in national multi district litigation. He also has extensive experience handling product liability, wrongful death, and catastrophic injury cases. Greg has been recognized as an outstanding trial

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lawyer on several occasions. In 2006, he received the Thomas E. Sullivan Award presented by the Kansas Trial Lawyers Association to "a talented young trial lawyer" whose "promising litigation career has brought credit and respect to himself and his profession." Greg's peers have selected him for inclusion in the listing of Kansas & Missouri Super Lawyers. He is listed as one of the top 100 trial lawyers in Kansas by The National Trial Lawyers. And the Litigation Counsel of America has named Greg as a Fellow of the invitation-only trial lawyer organization representing less than one-half of one percent of American lawyers. Greg is licensed to practice in Kansas and Missouri, as well as the United States District Court of Kansas, the United States District Court for the Western District of Missouri, and the United States Circuit Courts of Appeal, Eighth and Tenth Circuits He is a member of the Kansas and Missouri Bar Associations, Kansas City Metropolitan Bar Association, Johnson County (Kansas) Bar Association, Kansas Trial Lawyers Association, American Association of Justice, and Earl E. O'Connor American Inn of Court.

CHARLES SCHIMMEL. Chuck has successfully litigated complex legal matters and commercial disputes of all kinds for over twenty years. Chuck represents both individuals and businesses in state and federal trial and appellate courts in Kansas, Missouri and throughout the country. Chuck has expertise advising clients in a wide range of matters including consumer and commercial transactions, antitrust, and oil and gas royalty matters. Born and raised in Wichita, Kansas, Chuck graduated from Kansas State University with a B.A. in Economics in 1994 and earned his law degree from the University of Kansas School of Law in 1997. Following law school, Chuck began his career at a well-respected rural Kansas general practice law firm. He then moved to the Kansas City area to work with one of the country's largest international law firms handling pharmaceutical defense litigation. Since then, Chuck has litigated and tried cases involving various areas of the law including, class actions, antitrust cases, various contract disputes, shareholder derivative suits, bank fraud, professional malpractice claims, and oil and gas royalty underpayment matters. Chuck was selected for inclusion as a Super Lawyer Missouri and Kansas since 2017 and is rated as "excellent" by his peer lawyers.

RUTH ANNE FRENCH-HODSON. Focuses her practice on complex class actions and appeals. She has worked on both sides of multidistrict litigation and class actions. This experience allows her to understand what matters to both sides and effectively resolve disputes. She also capitalizes on her experiences as a federal clerk at both the trial and appellate levels to forcefully advocate for her clients. She understands the importance of developing discovery and trial records to preserve important issues if appellate review becomes necessary, as it often does. She is also firmly committed to providing pro bono services. Notably, she led an appellate team that secured a significant Missouri state appellate court victory ensuring that custodians of children who are entitled to counsel can access that help and that hearings in family court are full and fair for all participants. She also represents inmates presenting habeas petitions and in other pro bono appeals. At Yale Law School, Ruth Anne was active in Yale Law Women, serving on the board as Community & Outreach chair and co-chairing a nationally publicized report on gender and legal education, Yale Law School Students and Faculty Speak Up about Gender: Ten Years Later. Through her clinic, she spent two years assisting the New Haven Corporation Counsel with affirmative projects related to housing conditions, accessible taxis, and

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immigration detainers. Before attending law school, Ruth Anne was awarded a Rhodes Scholarship, which supported her graduate education at the University of Oxford.

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Sample of Class Cases Where One or More Attorneys in the Firm Represented Plaintiffs as Lead Counsel or Co-lead Counsel:

1. Nakamura v. Wells Fargo Bank, No. 17-4029-DDC (D. Kan.) (approval of class settlement on behalf of United States veterans against bank for unlawful repossession of vehicles); 2. In re EpiPen Marketing, Sales Practices and Antitrust Litigation, 17-MDL- 2785 (D. Kan.) (class certification motion pending before Judge Crabtree in multi-district litigation proceeding); 3. Harris v. Chevron, US.A., Inc. et al; No. 19-cv-355-SPS (E.D. Okla.) (royalty class conditionally certified for settlement purposes, settlement pending); 4. Cecil v. BP America Production Company; No. 16-CV-410-KEW (E.D. Okla.) (settlement class approved for RICO claim alleged on behalf of royalty owners); 5. McKnight Realty Co. v. Bravo Arkoma, LLC et al; No. CIV-17-308-KEW (E.D. Okla.) (royalty class conditionally certified for settlement purposes, settlement pending); 6. Bollenbach Enterprises Limited Partnership v. Oklahoma Energy Acquisitions, LP, et al., No. CIV-17-0134-HE (W.D. Okla.) (class settlement approved); 7. Eatinger v. BP America, No. 07-1266-EFM (D. Kan.) (contested class certified, improper royalty owner non-gathering deduction claims settled); 8. Hershey v. ExxonMobil, No. 07-1300-JTM (D. Kan.) (contested class certified, improper royalty owner deduction claims settled); 9. Freebird, Inc. v. Cimarex Energy Co., No. 08-CV-93 (Kan. Dist. Ct., Finney Cnty) (improper royalty owner deduction class claims settled, affirmed on appeal, 46 Kan. App. 2d 631,264 P.3d 500 (2011)); IO. Freebird, Inc. v. Merit Energy Co., No. 10-1154-KHV (D. Kan.) (contested class certified, improper royalty owner deductions claims settled); I 1. Wallace B. Roderick Revocable Living Trust v. XTO Energy Co., No.08- 01330-JTM (D. Kan.) (class certification denied and case dismissed); 12. Lenz v. Exxon Mobil, No. 07-CV-16 (Kan. Dist. Ct., Grant Cnty) (improper royalty owner deductions by failing to pay for helium settled with Hershey case, supra); 13. Wallace B. Roderick Revocable Living Trust v. Kansas Natural Gas, No. 09-CV-14 (Kan. Dist. Ct. Kearny Cnty.) (improper royalty owner deductions class certified and later settled); 14. Arkalon Grazing Ass 'n v. Chesapeake Operating, Inc., No. 09-1394-CM (D. Kan) (contested class certified, decertified and dismissed); 15. Chieftain Royalty Co. v. XTO Energy, Inc., No. CIV-11-29-FHS (E.D. Okla.) (royalty underpayment class conditionally certified for settlement purposes; settlement pending); 16. Fitzgerald Farms, Inc. v. Chesapeake Operating Co., No. CJ-10-38 (Beaver Co., OK) (royalty owner class certified, reversed on appeal, appellate ruling depublished, class settlement approved); I 7. Hitch Enterprises, Inc. v. Cimarex Energy Co., No. CIV-11-13-W (W.D. Okla.) (royalty underpayment class claims settled); 18. Marvin Chance, Jr. v. United States Tobacco Company, et. al., No. 05-CV- 112 (Kan. Dist. Ct., Seward Cnty.) (contested indirect purchaser antitrust class certified,

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and case settled as two state class just before trial, settlement at 2006 WL 1390382 (Kan. Dist. Mar. 8, 2006)); 19. Premier Pork, Inc. v. Rhone Poulenc, SA., et al., No. 00-CV-3 (Kan. Dist. Ct. Scott Cnty) ( contested indirect purchaser antitrust class certified, settled just before trial, 2006 WL 1388464 (Kan. Dist. Jan 31, 2006)); 20. Daric Smith v. Philip Morris, et. al., No. 00-CV-26 (Kan. Dist. Ct., Seward Cnty.) (contested indirect purchaser antitrust class certified, summary judgment granted and affirmed on appeal); 21. Dragon v. Vanguard Ind., Inc., No. 01-C-98 (Kan. Dist. Ct., McPherson Cnty.) (certified multi-state contested class action, overturned on appeal, 277 Kan. 776, 89 P.3d 908 (2004); multi-state class denied on remand, but reversed on appeal, 282 Kan. 349, 144 P.3d 1279 (2006); then recertified as a multi-state class on remand, appeal denied, and class settlement approved); 22. Loyd Smith v. Kansas Gas Service Co., et al., No. 01-C-29 (Kan. Dist. Ct., Reno Cnty) (contested class certified, trial and judgment for the class, overturned on appeal, 285 Kan. 33, 169 P.3d 1052 (2007)); 23. Gilley v. Kansas Gas Service Co., et al., No. 01-C-0157 (Kan. Dist. Ct. Reno Cnty.) (contested class certified, lost at trial); 24. Merriman v. Crompton Corp., 282 Kan. 433, 146 P.3d 162 (2006) ( established personal jurisdiction in international antitrust conspiracy after which the class case was settled); 25. In re Vitamin Antitrust Litigation, Master Case No. 98-C-4574 (Kan. Dist. Ct., Wyandotte Cnty.) (contested antitrust class certified, judgment taken for the class); 26. In re Union Pacific Railroad Empl. Prac. Litig., MDL No. 1597, 2005 WL 1027078 (D. Neb. March 31, 2005) (contested class certified; summary judgment on liability for plaintiff, reversed on appeal); 27. Stocking v. AT&T Corp., No. 03-0421-CV-W-HFS, (W.D. Mo.) (contested class certified, summary judgment granted plaintiff class, reversed on reconsideration); 28. Heath Merriman v. Cabot Corp., No. 2003 CV-115 (Kan. Dist. Ct., Pratt Cnty.) (multi-state indirect purchaser antitrust settlement class); 29. Anderson Contracting, Inc. v. Bayer AG, et al., No. CL-95959 (Iowa Dist. Ct. Polk Cnty.) (contested indirect purchaser antitrust class certified, affirmed on appeal, 776 N.W.2d 846 (2009), and later settled); 30. Critchfield Physical Therapy v. Taranto Group, No. 07-CV-8652 (Kan. Dist. Ct., Johnson Cnty.) ( contested TCP A class certified, affirmed on appeal, 293 Kan. 285, 263 P.3d 767 (2011), classwide settlement); 31. Fun Services v. Parrish Love d/b/a Asphalt Wizards, No.0816-CV00064, (Mo. Cir. Ct. Jackson Cnty.) (contested TCPA class certified, lost declaratory judgment action involving insurance policies); 32. Schell v. OXY, No. 07-1258-JTM, (D. Kan.) (contested class certified for house gas clause owners to obtain useable gas, summary judgment granted for the class,

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appeal upheld judgment in favor of the class, petition for writ of certiorari to the United States Supreme Court denied); 33. Fun Services v. StreetGlow, No.09-CV-02674 (Kan. Dist. Ct., Johnson Cnty.) (contested TCPA class certified, class settlement); 34. Anderson Office Supply, Inc. v. Advanced Medical Associates, P.A., No. 2009-CV-178 (Kan. Dist. Ct., Harvey Cnty.) (contested class certified, TCPA claims, affirmed on appeal, 47 Kan. App. 2d 140,273 P.3d 786, rev. denied (2012), settled); 35. Teague v. Bayer AG, No. 05-CVS-90 (N.C. Dist. Ct., Buncombe Cnty.) (indirect purchaser antitrust class action, dismissed, overturned on appeal, 2007 WL 2569668, class certified, multi-state settlement); 36. Freeman Industries, LLC v. Eastman Chemical Co., No. C34355-L (Tenn. Dist. Ct. Sullivan Cnty.) (indirect purchaser antitrust case, dismissed twice, reversed on appeal twice, and settled); 37. Sally Mussmann, et al. v. Wal-Mart Stores, Inc., et al, No. LACV-27486 (Iowa Dist. Ct., Clinton Cnty.) (class wage and hour claims settled); 38. Boles v. Anadarko, No. 08-CV-4 (Kan. Dist. Ct., Seward Cnty.) (improper royalty owner deductions, settled in Coulter v. Anadarko Petroleum Corp., 292 P.3d 289 (Kan. 2013)); 39. Cooper Clark Foundation v. Anadarko Petroleum Corp., No. 02-C-49 (Kan. Dist. Ct., Seward Cnty.) (improper royalty owner payments by affiliate sales, settled in Coulter, 292 P.2d 289, supra.); 40. Roderick v. Noble Energy, No. 09-CV-2 (Kan. Dist. Ct. Kearny Cnty.) (improper royalty owner deductions settled); 41. Roderick v. Osborn Heirs, No. 09-CV-15 (Kan. Dist. Ct., Kearny Cnty.) (improper royalty owner deductions, settled); Fun Services v. Hertz Equipment Rental, No. 08-CV-03944 (Kan. Dist. Ct., Johnson Cnty.) (TCPA class action settled; insurance coverage action pending); 42. Carlile v. Murfin Inc., et al., No. 13 CV 61, (Kan. Dist. Ct., Seward Cnty.) ( class action for underpayment of royalty by deduction of conservation fees settled a. v. Wal-Mart Stores, Inc., et al, No. Ol L 85 (Ill. Cir. Ct., Rock Island Cnty.) (class settlement approved). 43. DSR Investments LLC v. Devon Energy Production Company, L.P., No. CJ- 11-12 (Okl. Dist. Ct., Dewey Cnty.) (improper royalty deductions, class settlement approved); 44. Philip J Cornett and Ashcraft Group LLC v. Samson Resource Company, No. CJ-09-81 (Okl. Dist. Ct., Dewey Cnty.) (improper royalty deductions, class settlement approved); 45. Fawcett v. Oil Producers, Inc. of Kansas, No. 11-CV-90 (Kan. Dist. Ct., Seward Cnty.) ( contested royalty underpayment class certified and partial summary judgment granted to the class on liability), aff'd, 49 Kan.App.2d 194, 306 P.3d 318 (July 19, 2013 ), class certification untouched but summary judgment for plaintiff class reversed,

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352 P.3d 1032 (Kan. 2015) (remanded to district court for further proceedings, won class trial on improper deduction of Conservation fees, on appeal again) 46. Cardin Chiropractic & Acupuncture Clinic, P.A. (f/k/a Manfredi) v. Blue Cross Blue Shield ofKansas City, No. 05 l 6-CV32359 (Mo. Cir. Ct., Jackson Cnty.) (allied provider breach of contract, class settlement approved); 47. Imprelis Herbicide Marketing, Sales Practices and Products Liability Litig., No. 2:11-MDL-02284-GP (E.D. Pa.) (class settlement for defective herbicide); 48. Owens v. Dart Cherokee, No. 12-4157-JAR (D. Kan.) (improper royalty deductions, settled class-wide)-went to U.S. S. Ct.-Dart Cherokee Basin Operating Co. v. Owens, 135 S.Ct. 547 (2014). 49. Whisenant v. Strat Land Exploration Co., No. CJ-2014-4, (Okl. Dist. Ct., Beaver Cnty.) (improper royalty deduction class certified, reversed and remanded, revised class pending); 50. Whisenant v. Sheridan Production Co., No. CIV-15-81-M (W.D. Okla.) (improper royalty deductions); 51. Barraza v. Cricket Wireless, LLC, No. C 15-02471 WHA (N.D. Cal.) (putative consumer class action, settled individually) 52. Ann Cavlovic v. JC Penney Corporation, Inc., No. 27-CV-2042 (D. Kan.) (false advertisement, settled individually) 53. Hitch Enterprises v. Key Production Company, Inc., No. CJ-2017-01 (Okla. Dist. Ct., Texas County) (improper royalty deductions, class certification pending) 54. Shelly Nash Fitzgerald, as Trustee of the Nash Family Mineral Trust UTA dated October 27, 1992 v. Lime Rock Resources Operating Company, Inc., No. CJ-2017- 31 (Okla. Dist. Ct., Texas County (improper royalty deductions, settlement approved class wide). 55. Cooper Clark Foundation v. OXY USA Inc., No. 2017-CV-000003 (Kan. Dist. Ct., Grant County) (improper royalty deductions, class certified, appeal pending).

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Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Sharp Law LLP Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Diel, Isaac P 58.5 $650.00 $38,025.00 Diel, Isaac P 4.1 $700.00 $2,870.00 Hudson, Ryan P 6.1 $750.00 $4,575.00 Bradshaw, Sarah A 9.9 $500.00 $4,950.00 Emmott, Betse PL 0.3 $150.00 $45.00

TOTALS 78.90 $50,465.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 169 of 253 PageID# 11592

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Sharp Law LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $0.00 Filing / Misc. Fees $0.00 Overnight Delivery/Messengers $0.00 Photocopying $0.00 Postage $0.00 Service of Process Fees $0.00 Telephone / Fax $0.00 Transportation / Meals / Lodging $94.84 Litigation Fund Contributions $10,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $10,094.84 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 170 of 253 PageID# 11593

Exhibit A-22 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 171 of 253 PageID# 11594

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF CHRISTOPHER LE IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Christopher Le, hereby declare as follows:

1. I am a partner at the law firm of Straus & Boies LLP. I submit this declaration in

support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement

of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Straus & Boies and its attorneys

are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel . This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 1,114.5. The total lodestar for my firm is $654,847.00. My firm’s lodestar amount

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includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm’s attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm’s contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm’s lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $18,087.06 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $10,000 in

contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 173 of 253 PageID# 11596

Executed this 29th day of April 2021 in Fairfax, Virginia.

/s/Christopher Le ______

Christopher Le Straus & Boies, LLP 4041 University Drive Fifth Floor Fairfax, VA 22030 Telephone: (703) 764-8700 Fax: (703) 764-8704

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EXHIBIT A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 175 of 253 PageID# 11598

STRAUS & BOIES, LLP FIRM RESUME

Straus & Boies, LLP is widely recognized as a leading law firm in the fields of antitrust

and consumer protection class action litigation. With offices in Virginia, Florida, California,

Tennessee, and Colorado, the firm’s lawyers have successfully prosecuted antitrust and

consumer protection claims in federal and state courts throughout the United States.

Founded in 1995, the firm has been at the forefront of national efforts to bring to heel

corporations engaged in restraints of trade, consumer fraud, and other unlawful conduct. The

firm has been lead counsel in some of the largest class actions in the past decade, including the

vitamins and DRAM litigations. Straus & Boies lawyers have also led litigation efforts against

manufacturers of agricultural and refrigeration products for violations of competition laws and a

major insurance carrier for breach of its fiduciary duty to a certified class of policyholders.

Recognized by courts, private practitioners, and law enforcement authorities throughout the

United States as competent, experienced, and vigilant, Straus & Boies lawyers have recovered

hundreds of millions of dollars for consumers and businesses.

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The Firm’s Attorneys

David Boies

Mr. Boies is Senior Partner at Straus & Boies. His practice is focused on representing

individuals and businesses in antitrust and consumer protection litigation in state and federal

courts. Mr. Boies has a national reputation in the indirect purchaser antitrust litigation realm,

and has served as a speaker and panelist for the American Bar Association and other legal

organizations. Mr. Boies has served as sole lead or co-lead counsel in numerous antitrust and

consumer protection class actions. He is admitted to practice in all state and federal courts in the

Commonwealth of Virginia, as well as the United States Courts of Appeals for the Fourth and

Tenth Circuits.

Mr. Boies obtained his bachelor’s degree from the University of Redlands and his law

degree from William & Mary Law School (J.D. 1991). Prior to joining the Firm, Mr. Boies

represented individuals and corporations as an attorney in the Washington, D.C. offices of

national law firms in the practice areas of corporate litigation, international trade, and white

collar criminal defense.

Timothy D. Battin

Mr. Battin, the managing partner at Straus & Boies, LLP, has a wealth of experience in

complex litigation. He has served as lead counsel in numerous antitrust and consumer protection

class actions in state and federal courts around the country, resulting in recoveries of hundreds of

millions of dollars for consumers. Mr. Battin has prosecuted cases across a broad spectrum of

industries, including, pharmaceuticals, food additives, vitamins, agricultural and computer-based

products. He has served as lead or co-lead counsel in a number of cases including:

• Northwestern Mutual Insurance Litigation. Mr. Battin served as co-lead counsel in

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state and federal court actions alleging that Northwestern Mutual Life Insurance

Company breached its contractual and fiduciary duties to owners of certain investment

annuities it issued. This case was litigated in multiple jurisdictions and was ultimately

settled for $84 million.

• Dynamic Random Access Memory Antitrust Litigation. Mr. Battin served as co-lead

counsel in state and federal court actions alleging price fixing among makers of computer

memory chips. Settlements totaling more than $300 million were approved in the United

States District Court for the Northern District of California.

• Processed Egg Products Antitrust Litigation. Mr. Battin served as co-lead counsel for

indirect purchasers alleging a market allocation scheme in the egg industry.

Mr. Battin, a recognized authority on the prosecution of class actions, has lectured on

issues of coordination between attorneys general and private lawyers in class cases. He serves

on a Rule 23 Subcommittee for the District of Columbia Rules Advisory Committee. Mr. Battin

obtained his undergraduate degree in business from Old Dominion University (B.S. 1987) and

his law degree from the College of William & Mary (J.D. 1990). He is a member of the bars of

the District of Columbia, Virginia, Florida, and Missouri (inactive) and is also admitted to

practice before the United States District Courts for the Eastern District of Virginia, Eastern

District of Michigan and the District of Columbia, and the United States Courts of Appeals,

Fourth and District of Columbia Circuits.

Nathan M. Cihlar

Mr. Cihlar is a partner in the Virginia office of Straus & Boies. Throughout his career, he

has prosecuted complex and class action litigation with a focus on antitrust, consumer protection

and product liability claims. Since joining the firm, Mr. Cihlar has been highly involved in the

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litigation of numerous large, multi-faceted nationwide cases from inception to conclusion. He

has served in prominent roles in the litigation of, among others, antitrust class actions against the

manufacturers of Dynamic Random Access Memory, monosodium glutamate, oriented strand

board, LCD panels, and Cathode Ray Tubes. Additionally, Mr. Cihlar currently serves as the

trial planning committee chair in the Blue Cross Blue Shield antitrust litigation. Mr. Cihlar has

significant experience with litigation involving international defendants and foreign language

issues. He has served as foreign language discovery lead in both the LCD and CRT litigations.

In doing so, he has successfully represented numerous plaintiff classes and helped recover

hundreds of millions of dollars for consumers.

Mr. Cihlar obtained his bachelor’s degree from Georgetown University (B.S. Finance and

Marketing 1999), and his law degree from William & Mary Law School (J.D. 2004). He is

admitted to practice in Virginia, the District of Columbia and before the United States District

Court for the Eastern District of Virginia.

Christopher V. Le

Christopher Le is a partner in the Virginia office. He has extensive experience

representing groups of plaintiffs in complex civil cases in state and federal courts across the

country. Mr. Le has litigated numerous class actions from initial filing through trial or

settlement. He has negotiated the resolution of several significant antitrust and consumer cases

and help recover hundreds of millions of dollars for class members. Mr. Le has lectured on the

unique challenges professional objectors present to class settlements and strategies to deal with

them.

Mr. Le obtained his bachelor’s degree from The University of Virginia (B.A. 2004) and

his law degree from Case Western Reserve University (J.D. 2007, cum laude). He is admitted to

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practice in Virginia and the District of Columbia.

Mark J. Schirmer

Mr. Schirmer is a partner in the Tennessee office of Straus & Boies. He has

approximately thirty years of experience prosecuting and defending civil and criminal actions

arising out of complex business transactions in courts and before regulatory agencies throughout

the country.

Mr. Schirmer served as Senior Trial Attorney in the Eastern Regional office of the U.S.

Commodity Futures Trading Commission and served on a number of bar committees concerned

with litigation involving financial professionals and financial transactions. He is admitted to the

bars of New York and Tennessee, and is admitted to practice before the United States Courts of

Appeals for the Fourth, Sixth and Eleventh Circuits, and the United States District Courts for the

Southern and Eastern Districts of New York, the Eastern District of Michigan and the Western

District of Tennessee. He is a graduate of Fordham University’s School of Law and Macalester

College.

Barry Boughman

Mr. Boughman served as an Assistant United States Attorney for the District of Colorado

from 1986 to 1988, when he entered private practice. He also served as Law Clerk for the

Honorable Michael R. Enwall, District Court Judge for the 20th Judicial District in Boulder,

Colorado from 1984 to 1985. He obtained his bachelor’s degree from the University of Northern

Colorado (B.A. 1980) and his law degree from the University of Colorado School of Law (J.D.

1984). He is admitted to practice in Colorado as well as before the United States Court of

Appeals for the Tenth Circuit and the United States District Court for the District of Colorado.

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Steven M. Feder

Mr. Feder obtained his bachelor’s degree from Miami University (Ohio) (B.S. 1982) and

his law degree from the University of Colorado School of Law (J.D. 1985, Order of the Coif).

He is admitted to practice in Colorado and Illinois, as well as before the United States Supreme

Court, the United States Court of Appeals for the Tenth Circuit, and the United States District

Courts for the Districts of Colorado and Connecticut. He served as a prosecutor in Colorado’s

Eighteenth Judicial District from 1985 to 1990, before entering private practice.

Shinae Kim-Helms

Ms. Kim-Helms is a partner and represents consumers and businesses in cases involving

price fixing, monopolization, and other anticompetitive practices. Prior to joining Straus &

Boies LLP, Ms. Kim-Helms worked on cases involving patent and trademark infringement.

Since joining the firm in 2010, Ms. Kim-Helms has been involved in litigating cases against the

manufacturers of LCD panels, cathode ray tubes, lithium ion batteries, and auto parts.

Ms. Kim-Helms obtained her bachelor’s degree from Seoul National University (B.S.

Agrobiology), her master’s degree from Yonsei University (M.S. Biochemistry) and her law

degree from Golden Gate University, School of Law (J.D. 2005). Ms. Kim Helms' article on

licensing agreements was published in Les Nouvelles, a quarterly licensing journal published by

the Licensing Executives Society. Ms. Kim-Helms is fluent in Korean and Japanese. She is

admitted to practice in California and before the United States District Court for the Northern

District of California and the United States Patent and Trademark Office.

Joshua Callister

Mr. Callister is an associate attorney working in the Fairfax, Virginia office. He practices

primarily in complex antitrust cases, and has experience in both government regulatory work and

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complex litigation.

Prior to joining the firm in 2018, Mr. Callister worked as a director with a non-profit

organization in Washington D.C. focused on developing relationships between the United States

and the Middle East. Since joining the firm, he has worked on the Blue Cross Blue Shield,

Broilers Chicken, and Packaged Seafood antitrust litigations. A 2016 graduate of the George

Washington University Law School, Mr. Callister had the opportunity to clerk with a leading

D.C. regulatory firm, during which time he co-authored an article published in the Food and

Drug Law Institute, and previously consulted on multi-year complex litigation involving U.S.

sugar growers and high fructose corn syrup manufacturers. Mr. Callister speaks Japanese.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 182 of 253 PageID# 11605

Partial List of Recent Cases In Which Straus & Boies, LLP Has served As Lead Counsel

Dynamic Random Access Memory (DRAM)

Straus & Boies, LLP, served as co-lead counsel in these coordinated multi-state

proceedings against the manufacturers of Dynamic Random Access Memory chips (DRAM) for

the violation of various state’s antitrust/consumer protection laws. It was alleged that the DRAM

manufacturers entered into and engaged in a conspiracy in the United States and elsewhere to

suppress and eliminate competition by fixing the prices of DRAM. Straus & Boies, LLP

prosecuted the claims of indirect purchasers of DRAM since October 2004. Through the work of

Straus & Boies, LLP and its co-lead counsel, indirect purchasers were able to reach settlements

with all defendants totaling more than $300 million. These settlements were approved by the

United States District Court for the Northern District of California in June 2016.

Northwestern Mutual Life Insurance Annuity Litigation

Straus & Boies served as co-lead counsel on behalf of thousands of purchasers of

Northwestern Mutual Life Insurance Company (“Northwestern”) annuities. The lawsuit accused

Northwestern of deliberately stripping annuity policyholders of their dividend rights. Straus &

Boies litigated the case in multiple jurisdictions. The case went to trial, where Straus & Boies’

clients won a verdict on all material issues. Ultimately, the case settled for $84 million.

Vitamins

As lead counsel in coordinated multi-state proceedings of more than 50 indirect purchaser

classes and parens patriae actions filed in 23 separate state jurisdictions against the international

manufacturers of bulk vitamins, Straus & Boies negotiated and finalized a series of settlements

with the defendants. The first settlement secured by Straus & Boies was at that time the largest

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ever indirect purchaser antitrust settlement. Straus & Boies’s efforts in successfully resolving

the state vitamins indirect purchaser actions included structuring, implementing, and leading

coordinated alternative dispute resolution proceedings sanctioned by state courts throughout the

country, and involving scores of plaintiffs’ counsel, numerous counsel for foreign and domestic

defendants, and the State Attorneys General.

Food Additives

As sole lead counsel for more than 10 indirect purchaser state class action claims filed

across the country, Straus & Boies effectively advanced the claims of indirect purchasers against

the manufacturers of food additives for an illegal price-fixing conspiracy that affected consumer

prices for well over a decade. The cases allege that the major manufacturers of certain food

additives conspired to fix prices during the period January 1, 1990 through 2002. Straus & Boies

received final approval of a global settlement which provided millions to the affected class

members.

Eggs

Straus & Boies, LLP was co-lead counsel of indirect purchasers across the country and in

17 jurisdictions alleging a conspiracy to fix the prices of eggs. This litigation involved

complicated claims related to cage space restrictions in a multi-billion dollar industry.

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Partial List of Other Actions Prosecuted by Straus & Boies

Antitrust Actions

Blue Cross Blue Shield

1. In re: Blue Cross Blue Shield Antitrust Litigation, No. 2:13-cv-20000-RDP (N.D. Ala.).

Straus & Boies, LLP has been involved in ongoing representation of plaintiff subscribers

of the Individual Blue Plans including 60 defendants from across the nation, as well as

the Blue Cross Blue Shield Association. Partners of our firm serve prominent roles,

including chair of the trial planning committee. This action seeks to recover damages for

classes of subscribers caused by an ongoing conspiracy amongst the Blues to allocate

markets in violation of the Sherman Act.

Broilers Chicken

2. In re: Broiler Antitrust Litigation, No. 1:16-cv-08637 (N.D. Ill.).

Straus & Boies, LLP has been involved in ongoing representation of commercial and

institutional indirect purchaser plaintiffs against broiler chicken producers for conspiring

to fix, raise, maintain and stabilize the price of broiler chicken meat sold in the United

States since as early as January 1, 2008. Broilers sold in the United States are controlled

by a small number of large producers all of which are involved with this conspiracy.

Packaged Seafood

3. In re: Packaged Seafood Products Antitrust Litigation, No. 3:15-md-02670-JLS-MDD

(S.D. Cal.).

Straus & Boies, LLP has been involved in ongoing representation of end-payer plaintiffs

against major canned tuna fish manufacturers, including Bumble Bee Foods LLC,

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StarKist Company, and Tri-Union Seafoods LLC for conspiring to fix the prices of tuna

sold in the United States beginning on August 1, 2008 in violation of the Sherman Act

and of the Clayton Act. Defendants agreed to artificially increase prices in spite of falling

consumer demand, which continues to harm plaintiffs today.

Monosodium Glutamate

4. Ashley v. Archer Daniels Midland Co., et al., Circuit Court of DeKalb County, Alabama, CV-95-336, Co-lead Counsel.

5. Caldwell, et al. v. Archer Daniels Midland Co., et al., Circuit Court of Coosa County, Alabama, Civil Action No. CV-96-17, Co-lead Counsel.

6. Madelon J. Lief, et al. v. Archer Daniels Midland Co., Circuit Court of Dan County, Wisconsin, Civil Docket No. 02CV3697.

Vitamins

7. Donaldson, et al. v. Degussa Huls Corporation, et al., Circuit Court of Cullman Co. Alabama, C.A. No. 99-406, Co-lead Counsel.

8. Giral, et al. v F. Hoffman LaRoche Ltd., et. al., Superior Court of the District of Colombia, Civil Division, Case No. 0007467-98, Lead Counsel.

9. Graham v. Hoffman LaRoche, et al., Superior Court for the State of California, County of Yolo, No. CV 98-00046, J.C.C.P. No. 4076, Executive Committee.

10. Shaklee Corp. v. Degussa-Huls Corp, et al., Superior Court of San Francisco County, California, Case No. 308636, J.C.C.P. Nos. 4090 and 4096.

11. In re Vitamins Antitrust Litigation, United States District Court for the District of Columbia, MDL 1285, Executive Committee and Liaison Counsel.

Pharmaceuticals

12. In re Brand-Name Prescription Drugs Antitrust Litigation, United States District Court for the Northern District of Illinois, MDL 997.

13. In re Ciprofloxacin Hydrochloride Antitrust Litigation, United States District Court for the Eastern District of New York, MDL 1383.

14. Drug Mart Pharmacy Corporation v. Abbot Laboratories, et al., Supreme Court of the State of New York, County of Kings, No. 29126-99.

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15. Durrett v. The Upjohn Co., et al., Circuit Court of Tuscaloosa County, Alabama, Civil Action No. CV-97-170, Co-lead Counsel.

16. Goda, et al. v. Abbott Laboratories, Inc., Superior Court for the District of Columbia, Civil Docket No. 01445-96.

17. Holdren, et al. v. Abbott Laboratories, Inc., District Court of Johnson County, Kansas, Case No. 96C15994.

18. Huggins, et al. v. Abbott Laboratories, Inc., et al., Circuit Court for Chambers County, Alabama, Case No. CV-96-024-Cl.

19. Karofsky v. Abbott Laboratories, Inc., et al., Superior Court of Cumberland County, Maine, Civil Docket No. 95-1009.

20. Kerr v. Abbott Laboratories, Inc., et al., District Court of Hennepin County, Minnesota, No. MC-96-002837.

21. Long v. Abbott Laboratories, Inc., et al., General Court of Justice Superior Court Division for Mecklenburg County, North Carolina, Civil Action No. 97 CVS 8289.

22. McLaughlin, et al. v. Abbott Laboratories, Inc., Superior Court for Yavapai County, Arizona, No. 1-CA-SA-96-0215.

23. Meyers v. Abbott Laboratories, Inc., et al., Circuit Court for Davidson County, Tennessee, No. 970612.

24. Scholfeld v. Abbott Laboratories, Inc., et al., District Court for Dane County, Wisconsin, No. 96-CV-0460.

25. Wood v. Abbott Laboratories, Inc., et al., Circuit Court of Oakland County, Michigan, No. 96-5125610CZ.

26. Yasbin, et al. v. Abbott Laboratories, Inc., Circuit Court for the Eleventh Judicial District for Dade County, Florida, C.A. No. 97-1141-CA 03.

Vitamin C

27. Audette v. Hebei Welcome Pharmaceutical Co. Ltd., et al., Commonwealth of Massachusetts, Case No. 2005-00182-C.

28. In re Vitamin C Antitrust Litigation, United States District Court for the Eastern District of New York, MDL No. 1738, Co-Lead Counsel.

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Polyester

29. Augusta Sullivan and Rose Marie Farina v. Wellman, Inc., et al., Commonwealth of Massachusetts, Case No. 02-4872 C.

30. Briscoe, et al. v. DuPont E.I. Nemours & Co., et al., Superior Court for the District of Columbia, C.A. No. 02ca0010508.

31. Polyester Staple Cases, Superior Court of California, Judicial Council Coordination Proceeding No.: JCCP No. 4278.

32. Thomaston Mills, Inc., et al. v. DuPont E.I. Nemours & Co., et al., United States District Court for the Western District of North Carolina, Civil Action No. 3:02-CV-474-V.

DRAM Microchips

33. In re Dynamic Random Access Memory (DRAM) Antitrust Litigation, United States District Court for the Northern District of California, MDL No. 1486, Co-Lead Counsel.

34. Hamilton v. Elpida Memory Inc., et al, Commonwealth of Massachusetts, County of Suffolk, The Superior Court, Case No. 04-3264.

Air Industry

35. In re Air Cargo Shipping Services Antitrust Litigation, United States District Court for the Eastern District of New York, Case No. 06-MD-1775.

36. In re American Airlines Antitrust Litigation, United States District Court for the District of Kansas, Case No. 99-1187-MLB, Chair of Executive Committee.

37. In re International Air Transportation Surcharge Antitrust Litigation, United States District Court for the Northern District of California, Case No. 06-cv-1793.

38. McCoy-Johnson, et al. v. Northwest Airlines, Inc. and Northwest Airlines Corp., United States District Court for Western District of Tennessee, Western Division, No. 99-2994 GV, Chair of Executive Committee.

Aspartame

39. In re Aspartame Antitrust Litigation, United States District Court for the Eastern District of Pennsylvania, No. 06-CV-1732, Co-lead Counsel.

Intel

40. Dressed to Kill Custom Draperies v. Intel Corp., United States District Court for the Northern District of California, C 05 3272.

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41. In re Intel Corporation Microprocessor Antitrust Litigation, United States District Court for the District of Delaware, C 05 485

42. Juan v. Intel Corp., United States District Court for the Northern District of California, C 05 3271.

43. Kinder v. Intel Corp., United States District Court for the Northern District of California, C 05 3273.

44. Rush v. Intel Corp., United States District Court for the Northern District of California C 05 3277.

Microsoft

45. Crain v. Microsoft Corporation, et al., Superior Court for the State of California, County of Yolo, No. CV 99-1740, J.C.C.P. No. 4106.

46. Dunham v. Microsoft Corporation, et al., Superior Court of the State of California, County of Sonoma, No. 223291, J.C.C.P. No. 4106.

47. Saams, et al. v. Microsoft Corporation, et al., Superior Court for the State of California, County of San Francisco, CV 308015, J.C.C.P. No. 4106.

Other Products and Industries

48. In re Disposable Contact Lens Antitrust Litigation, United States District Court for the Middle District of Florida, Jacksonville Division, MDL 2626.

49. In re Lithium Ion Batteries Antitrust Litigation, United States District Court for the Northern District of California, Oakland Division, MDL 2420.

50. In re Automotive Parts Antitrust Litigation, United States District Court for the Eastern District of Michigan, Southern Division, Case No. 12-cv-2311.

51. In re Cathode Ray Tube (CRT) Antitrust Litigation, United States District Court for the Northern District of California, Case No. 07-cv-5944.

52. In re Citric Acid Antitrust Litigation, United States District Court for the Northern District of California, MDL 1092.

53. In re Commercial Tissue Products, United States District Court for the Northern District of Florida, Gainesville Division, MDL 1189, Case No. 97-CV-128.

54. In re Flash Memory Antitrust Litigation, United States District Court for the Northern District of California, Case No. 07-cv-086.

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55. In re Foreign Currency Conversion Fee Antitrust Litigation, United States District Court for the Southern District of New York, MDL 1409.

56. In re High Fructose Corn Syrup Antitrust Litigation, United States District Court for the Central District of Illinois, MDL 1087.

57. In re Methionine Antitrust Litigation, United States District Court for the Northern District of California, MDL 1311.

58. In re Online DVD Rental Antitrust Litigation, Unites States District Court for the Northern District of California, MDL 2029.

59. In re OSB Antitrust Litigation, United States District Court for the Eastern District of Pennsylvania, Case No. 06-826, Co-lead Counsel.

60. In re Processed Egg Products Antitrust Litigation, United States District Court for the Eastern District of Pennsylvania, Case No. 08-md-2002, Co-lead Counsel.

61. In re Refrigerant Compressors Antitrust Litigation, United States District Court for the Eastern District of Michigan, Case No. 2:09-02042.

62. Robbins, LLC v. Cabot Corporation, et al., United States District Court for the District of Massachusetts, Case No. 03-CV-11072DPW.

63. Seven Up Bottling Company of Jasper, Inc. v. Archer Daniels Midland Co., et al., Circuit Court of Walker County, Alabama, Civil Action No. 95-436, Co-lead Counsel.

64. In re Static Random Access Memory (SRAM) Antitrust Litigation, United States District Court for the Northern District of California, Oakland Division, Case No. 07-cv-1819. 65. In re TFT-LCD (Flat Panel) Antitrust Litigation, United States District Court for the Northern District of California, San Francisco Division, Case No. 07-cv-1827.

66. Thomas and Thomas Rodmakers, Inc., et al. v. Newport Adhesives and Composites, Inc. et al. United States District Court Central Division, No. CV-99-07796-GHK (CTx).

67. In re Hypodermic Products Antitrust Litigation, United States District Court for the District of New Jersey, Case No. 05-cv-1602.

68. In re Residential Telephone Lease Contract Litigation, Southern District of Alabama, MDL 1165, Co-lead Counsel.

69. Park Surgical Co. Inc., et al. v. Becton Dickinson & Company, Civil Action No. 05 CV 5678 (E.D. Pa.)(CMR).

70. Smith v. GTE Corp., et al., United States District Court for the Middle District of

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Alabama, Case No. 97-M-1025, Co-lead Counsel.

71. Southeast Missouri Hospital, Saint Francis Medical Center v. C.R. Bard Inc., United States District Court for the Eastern District of Missouri, Southeastern Division, Case No. 07-cv-031, Co-lead Counsel.

72. Sparks, et al. v. AT&T Corporation, et al., Circuit Court, Third Judicial Circuit, Madison County, Illinois, Case No. 96-LM-983.

73. Sparks, et al. v. Lucent Technologies, et al., Circuit Court, Third Judicial Circuit, Madison County, Illinois, Case No. 01-L-1668.

74. Wilson v. Toys R Us, et al., Circuit Court of Tuscaloosa County, Alabama, Civil Action No. CV-96-574, Co-lead Counsel.

Securities Actions

75. In re Alliance, Franklin/Templeton, Bank of America/Nation Funds, and Pilgrim Baxter [Franklin Templeton Subtrack] v. Sharkey Iro/Ira v. Franklin Resources, et al., United States District Court for the District of Maryland, Case No. 04-MD-15862.

76. Casey v. Prudential Securities, Inc., Supreme Court of the State of New York, County of Albany, Index. No. 3462-97.

77. In re Medpartners Securities Litigation, United States District Court for the Northern District of Alabama, CV-98-B-0067-S.

78. In re Mutual Funds Investment Litigation, United States District Court for the District of Maryland, MDL 1586.

79. In re NASDAQ Market-Makers Antitrust Litigation, United States District Court for the Southern District of New York, MDL 1023.

80. Milne v. Mercury Finance Co., et al., United States District Court for the Northern District of Illinois, No. 97-C-1536.

81. Ronald Lankford v. Jos. A. Banks Clothiers, Inc., Circuit Court of Madison County, Alabama, Case No. CV03-204LHL.

82. In re Vesta Insurance Group, Inc. Securities Litigation, United States District Court for the Northern District of Alabama, CV 98-AR-1407-S, Liaison Counsel.

83. Vivian Bernstein v. Janus Capital Management, LLC, et al., United States District Court, District of Colorado, Case No. 03-B-1798.

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Products Liability Actions

84. In re Bridgestone/Firestone, Inc. ATX, ATX II and Wilderness Tires Products Liability Litigation, United Sates District Court for the Southern District of Indiana, Indianapolis Division, MDL 1373, (Tires).

85. In re Cigarette Litigation, United States District Court for the Northern District of Georgia, CV-0447 (MDL 1342).

86. Hodge, et al. v. Eastman Chemical Company, Circuit Court of Jefferson County, Tennessee, Civil Action No. 16.351 IV, Co-lead Counsel, (Photography Chemicals).

87. Rampey v. Novartis Consumer Health, Inc., Circuit Court of Chambers County, Alabama, CV-97-174, Co-lead Counsel, ( Ex-Lax).

88. In re Zurn Pex Products Liability Litigation, United States District Court for the District of Minnesota, Case No. 08-md-1958, Class Counsel.

Miscellaneous Actions

In addition to the above listed suits, Straus & Boies, LLP has been involved in numerous other fields of litigation:

89. ALCOHOL - Straus & Boies, LLP lead the fight against numerous alcoholic beverage manufacturers and distributors for illegally advertising to underage children. Ayman R. Hakki, et al. v. Zima Company, et al., Superior Court for the District of Columbia, Case No. 1:03 CV 02621; Randy Kreft and Colleen Kreft, et al. v. Zima Beverage Company, et al., District Court, City & County of Denver, Colorado, Case No. 03-CV-9229; Ronald P. Wilson, Andrea B. Wilson and Joseph A. Wilson, et al. v. Zima Company, et al., Superior Court, County of Mecklenburg, State of North Carolina, Case No. 04-CV-626.

90. GENETICALLY MODIFIED CROPS – Straus & Boies, LLP has also been involved in litigation regarding broad contamination due to genetically modified crops. Blades, et al. v. Monsanto Co., United States District Court for the Southern District of Illinois, CV 00- 4034-DRH (soy); In re Genetically Modified Rice Litigation, United States District Court for the Eastern District of Missouri, No. 4:06-MD 1811 CDP (rice).

91. PAN AM VICTIMS – Straus & Boies, LLP represents family members of the victims of the terrorist act on Pan Am Flight 103. Curtis W. Fisher, et al. v. Abdel Basset Ali Mohmed Al-Megrahi, et al., D.D.C. 04-02055 (HHK); Lawrence P. Fisher II v. Great Socialist People’s Libyan Jamahiriya, et al., D.D.C. 05-2454 (HHK).

92. Care Pharmacies, Inc. v. Purdue Pharma, L.P., et al., United States District Court for the Southern District of New York, Case No. 04-CV-3890 (Class action alleging damages based on abuse of patent for OxyContin)

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93. Derek S. Lynn v. Hyundai Motor America, Inc., Circuit Court of Madison County, Alabama, Civil Action No. CV-03-412.

94. In re FedEx Ground Package System, Inc. Employment Practices Litigation, United States District Court for the Northern District of Indiana, South Bend Division, Case No. 05-MD-527.

95. In re Humana, Inc. Managed Care Litigation, United States District Court for the Southern District of Florida, MDL 1334, Executive Committee. (Class action against managed-health care organizations for nonpayment).

96. Marleen M. LaPlant v. The Northwestern Mutual Life Insurance Company, State of Wisconsin, Circuit Court, Milwaukee County, Case No. 08-cv-011988, Co-lead Counsel.

97. Poulos, et al. v. Caesar’s World, Inc., et al., United States District Court for the District of Nevada, CV-S-94-1126-DAE (RJJ) (Misrepresentation of odds in slot machines).

98. Prewitt Enterprises, Inc., v. Organization of Petroleum Exporting Countries, United States District Court for the Northern District of Alabama, Case No. CV-00-B-0865-S.

99. Thomas Miller and Noel Collette v. Deluxe Corporation, First Judicial District, District Court of Dakota County, Minnesota, Civil Action No. 19-CO-03-6487 (Checks Unlimited).

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Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Straus & Boies, LLP Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Battin, Timothy P 245.6 $750.00 $184,200.00 Le, Christopher P 511 $545.00 $278,495.00 Schirmer, Mark P 221.8 $650.00 $144,170.00 Kim-Helms, Shinae P 57.1 $505.00 $28,835.50 Callister, Joshua A 20 $360.00 $7,200.00 Hare, Casey PL 55.7 $205.00 $11,418.50 McGinty, Tara PL 3.3 $160.00 $528.00

TOTALS 1114.50 $654,847.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 194 of 253 PageID# 11617

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Straus & Boies, LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $156.90 Filing / Misc. Fees $0.00 Overnight Delivery/Messengers $0.00 Photocopying $479.18 Postage $0.00 Service of Process Fees $0.00 Telephone / Fax $71.17 Transportation / Meals / Lodging $7,379.81 Litigation Fund Contributions $10,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $18,087.06 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 195 of 253 PageID# 11618

Exhibit A-23 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 196 of 253 PageID# 11619

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF DANIEL K. BRYSON IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Daniel K. Bryson, hereby declare as follows:

1. I am a partner at the law firm of Whitfield Bryson LLP. I submit this declaration in

support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement

of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Whitfield Bryson LLP and its

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 216.9. The total lodestar for my firm is $72,600.00. My firm’s lodestar amount includes

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 197 of 253 PageID# 11620

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $15,889.61 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $15,000 in

contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 27th day of April, 2021 in Raleigh, North Carolina.

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Daniel K. Bryson WHITFIELD BRYSON LLP 900 West Morgan Street Raleigh, NC 27603 (919) 600-5000 [email protected]

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Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 200 of 253 PageID# 11623

~ ~ WHITFIELD BRYSON LLP ATTORNEYS AT LAW

FIRM RESUME Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 201 of 253 PageID# 11624

Whitfield Bryson LLP Firm Resume Page 2 of 15

FIRM PROFILE

With offices located in Raleigh, North Carolina; Madisonville, Kentucky; Nashville, Tennessee; Charleston, South Carolina; and Los Angeles, California, Whitfield Bryson LLP is dedicated to representing plaintiffs in class actions, mass torts, and individual actions in courts throughout the United States. Founded in January 2012, the firm was created by a merger of three firms with decades of experience representing plaintiffs in complex litigation. Whitfield Bryson LLP has since expanded, litigating consumer fraud domestically and internationally.

FIRM RESUME Attorney Profiles

John C. Whitfield Founding Partner

For over 38 years, John has been one of the premier trial attorneys in Kentucky and Tennessee. He has represented numerous injured parties in the Commonwealth of Kentucky, Tennessee, and throughout the southeastern United States. He has concentrated primarily on complex civil litigation cases, and over his career has brought to settlement or judgment over 45 cases in excess of a million dollars each. John is certified as a civil trial specialist by the National Board of Trial Advocacy and has represented individuals in all walks of life against negligent workplace practices, reckless physicians, predatory businesses, and inattentive truck and automobile drivers among many others. John has an additional concentration in the Nashville, Tennessee area of representing motorcyclists who have been injured through no fault of their own.

John graduated with distinction from the University of Kentucky in1989, and then attended law school at the university, obtaining his J.D. in 1982. Throughout his career, John has represented scores of individuals who have been the victims of medical negligence, defective drugs, and medical devices, obtaining verdicts and settlements in both state and federal courts. He has handled cases for landowners victim to fraudulent mine royalty practices, for subsidence caused by coal mining, for homeowners whose homes and business contained defective concrete, and for Kentucky residents who were overcharged for premium insurance taxes.

John is a frequent lecturer of litigation subjects with the Kentucky Justice Association and American Association for Justice and has been recognized as a Kentucky Super Lawyer multiple times. He is AV rated by the Martindale-Hubbell rating service.

Daniel K. Bryson Founding Partner

Dan is a founding partner of the firm and is one of the nation’s most respected and experienced attorneys in the country in the area of consumer class actions and mass torts. Dan also has significant experience working with attorneys, funders and other partners on international litigation projects in the Courts in Amsterdam, the United Kingdom, Belgium, France, Spain and Portugal, among others.

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For over 32 years, Dan has handled hundreds of insurance related disputes, including first party bad faith insurance cases, and business interruption cases. Dan has written and taught numerous continuing legal education courses on a variety of insurance related topics. Dan and members of his firm are well equipped and dedicated to handling these cases on behalf of all entities who have had improperly denied claims.

Dan is a frequent lecturer and writer on a variety of consumer class action, insurance, and mass tort related disputes. He has been quoted by a variety of media outlets over the years including the Wall Street Journal, Washington Post, New York Times, Law360 and Lawyers Weekly to name a few. He has been named as a member of the Legal Elite and Super Lawyers in North Carolina on numerous occasions. He has been awarded the designation of one of the Top 25 lawyers in Raleigh by Charlotte Magazine for a number of years including 2020.

Dan is on the Executive Board and Vice-President of the Public Justice Foundation Board. Public Justice is a nationwide public interest law firm. See www.publicjustice.net for more information about this great organization. Dan is also an adjunct professor at Campbell Law School in Raleigh, NC where he teaches “Introduction to Class Actions and Multi-district litigation.” Dan is also the current Board Chair of Theatre Raleigh and enjoys running, playing the guitar, and golf in his free time.

Each year, Dan and members of his firm run a marathon. Last year, they ran in the St. George Marathon in St. George Utah. In 2018, they ran in the New York Marathon.

Scott C. Harris Managing Partner

Scott’s practice is focused on fighting for individuals and homeowners in complex litigation, including construction defect, mass tort, product liability, and wrongful death litigation. Scott has played a key role in securing substantial verdicts and settlements in a variety of cases, including a multi-million dollar verdict in favor of homeowners for a developer’s unfair and deceptive advertising and shoddy road construction, a legal malpractice case, and several defective condominium construction cases.

Scott earned his law degree from Wake Forest University School of Law in 2006 and his Bachelor of Arts from Hampden-Sydney College, in 2001. While at Hampden-Sydney College, Scott was Chairman of the Honor Committee and a member of the national leadership honor Society, Omicron Delta Kappa. Scott was named to the Super Lawyers' Rising Stars list as one of the top up-and-coming attorneys in North Carolina for 2010 and 2012-2018 and selected for inclusion in Business North Carolina Legal Elite for 2013.

Matthew E. Lee Partner

For the last 10 years, Matt has focused his practice on fighting for consumers in complex litigation. Matt has been recognized for his leadership on class actions and product liability matters. Since 2012, he has been regularly selected to Super Lawyers as a top-rated attorney in

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“Class Action & Mass Torts” practice area and written for a national publication on product liability cases. Matt is a frequent author and lecturer on product liability, construction, and insurance topics in North Carolina. Matt takes great pride in being part of a firm that stands shoulder to shoulder with its clients against some of the largest corporations in the world.

Matt handles complex litigation, primarily construction defect, product liability, business disputes, and wrongful death cases, and has secured substantial verdicts and settlements in a variety of matters, including multi-million dollar verdicts for homeowners associations in construction defect litigation and large settlements in class actions, product liability, and employment cases.

Matt is a graduate of Leadership Raleigh 25 with the Greater Raleigh Chamber of Commerce and co-chair of the American Association for Justice (AAJ) Trial Advocacy Competition in Raleigh, NC.

Matt earned his law degree from Wake Forest University School of Law in 2006 and his Bachelor of Arts from The Catholic University of America, cum laude, in 2001. While at Wake Forest, Matt was the 2005 Zeliff Trial Competition Champion, a regional finalist at the 2006 American Association for Justice (AAJ) Trial Advocacy Competition, the AAJ Student Chapter President, and was selected as a member of the Order of Barristers. In addition, Matt spent several months clerking for the United States Attorney’s Office in Greensboro, North Carolina.

Caroline Ramsey Taylor Partner

Caroline is a partner focusing her practice on complex civil litigation and personal injury. After clerking for Whitfield Bryson LLP during the summer of 2012, she officially joined the firm in March 2013, and actively practices in both the firm’s Nashville and Kentucky offices. Caroline graduated magna cum laude from the University of Louisville Brandeis School of Law, where she completed law school in just two and a half years. While in law school she was on the University of Louisville Law Review (Volume 50) and was also a member of Law Students for Justice (law school division of AAJ). Caroline received her bachelor's degree from Western Kentucky University, where she graduated summa cum laude with a bachelor’s degree in Corporate and Organizational Communication and a minor in Marketing.

Caroline has been appointed class counsel in numerous cases including Norman et al. v. Nissan North America, Inc. et al., Case No. 3:18-cv-534 (M.D.TN); Weckworth et al. v. Nissan North America et al., Case No. 3:18-cv-588 (M.D.TN); Cool v. L&B Oil and Gas, Inc., Case No. 16-CI-356 (Pike Co., Ky. Cir. Ct.), and Appalachian Land Co. v. EQT Production Company, Case No. 7:08-139-KKC (E.D. KY).

Caroline is a member of the American Association of Justice (AAJ) and is currently the Past Chair for the Railroad Section of AAJ. Caroline also serves on the Board of Governors for AAJ as the Revitalization Member for Tennessee. She is an active member and serves on the Executive Board of Directors of the Tennessee Trial Lawyers Association. She was recently included in The Best Lawyers in America 2020 Edition for Personal Injury Litigation, and was

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selected by the National Academy of Personal Injury Attorneys as a Top 10 Personal Injury Attorney in Tennessee Under Age 40, Top 40 Litigation Lawyer Under 40 for the state of TN in 2018, and as a “Top 40 Under 40” by The National Trial Lawyers. Additionally, she was appointed to the Tennessee Bench & Bar Committee.

Martha Geer Senior Counsel

Judge Martha Geer has a combination of experience that few attorneys possess and clients find invaluable. She has practiced for more than two decades as a respected litigator and appellate advocate and served for more than 13 years as a rarely-reversed appellate judge. As a trial lawyer and board-certified appellate specialist, Judge Geer is known for obtaining cutting-edge and precedent-setting victories in a diverse set of practice areas, including consumer protection, ERISA, environmental, securities, labor and employment law, antitrust and trade regulation, contingent commercial litigation, and civil rights litigation.

Judge Geer received her B.A. summa cum laude from Bryn Mawr College and her J.D. with high honors from the University of North Carolina School of Law where she was a Morehead Fellow (a merit-based full scholarship) and served as Managing Editor of the North Carolina Law Review.

Following law school, Judge Geer joined Paul Weiss, one of the top law firms in the country where she represented corporate clients in class actions, shareholder litigation, and commercial disputes. Subsequently, she was a partner with two leading North Carolina plaintiffs’ firms (a founding member of the second firm) and represented plaintiffs in a wide range of complex civil litigation, including both class actions and individual cases.

She was first elected to the North Carolina Court of Appeals in 2002. In 2010, because of her reputation as a fair and impartial judge, she garnered strong bipartisan support that resulted in her winning re-election by a 20-point margin. During her tenure on the Court, Judge Geer heard more than 3,800 appeals, authored more than 1,350 opinions, and had her opinions reversed less than 2% of the time. She left the Court of Appeals to become a partner at Cohen Milstein Sellers & Toll LLP, a leading plaintiffs’ class action firm, and founded its Raleigh office. In October 2019, she joined Whitfield Bryson LLP.

Judge Geer is a highly sought-after teacher of continuing education programs for both judges and lawyers. As a trial and appellate lawyer, she has been regularly recognized in The Best Lawyers in America, most recently (2018, 2019, and 2020 eds.) in the areas of appellate practice and mass tort/class actions. Prior to joining the bench, she was selected by Business North Carolina as one of North Carolina’s “Legal Elite.”

Jeremy R. Williams

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Attorney

Jeremy focuses his practice on class actions and other complex litigation. Since joining the firm in 2014, Jeremy has prosecuted cases nationwide against some of the largest companies in the world – ranging from cases involving millions of dollars in unpaid sales commissions by one of the largest technology companies in the Fortune 500 rankings to class actions for deceptive products and fraudulent pricing schemes against numerous Fortune 500 companies. Jeremy has also represented property owners in lawsuits related to defective construction of residential and commercial real estate. His work has led to the recovery of tens of millions of dollars for consumers.

Jeremy was named to the Super Lawyers' Rising Stars list as one of the top up-and-coming class action attorneys in North Carolina for 2018 through 2020. He is a member of the American Association for Justice as well as the North Carolina Advocates for Justice. He has served on the board of directors for several non-profit organizations and is currently the president of the Young Lawyers Division of the Wake County Bar Association. Jeremy graduated law school from Campbell University School of Law and earned his MBA from North Carolina State University. He received his bachelor’s in sport and event management in 2010 from Elon University.

Patrick M. Wallace Attorney

Patrick is an associate in Whitfield Bryson LLP’s litigation practice, with a focus on complex litigation, including consumer class actions, multi-district litigation, and qui tams. He focuses his nationwide practice on representing individuals and entities who have been the victims of defective products and corporate misconduct.

Patrick is entrusted by his clients and peers to successfully engage in every aspect of his cases, including arguing dispositive motions, formulating and executing discovery plans, working with experts, and conducting crucial depositions. Patrick takes on leadership roles in his cases, owing to his deep experience in nationwide litigation.

During his practice Patrick has served integral roles in several class actions. His recent experience includes litigating and settling North Carolina landlord-tenant eviction fee litigation cases against Mid-America Apartment Company, the NRP Group, and Southwood Realty Company. Patrick has also served important roles in nationwide litigation, including In re Lumber Liquidators Chinese-Manufactured Laminate Flooring Durability Marketing and Sales Practices Litigation (MDL No. 2743), In re Windsor Windows Wood Clad Windows Products Liability Litigation (MDL No. 2688), Smith v. Floor and Decor Outlets of America, Inc. (N.D. Ga.); and In re Outer Banks Power Outage Litigation (E.D.N.C.). Patrick also has extensive experience investigating and litigating qui tam cases, including through trial.

Patrick joined the firm in 2015 after completing a judicial clerkship with the Hon. Catharine R. Aron, Chief Judge for the United States Bankruptcy Court for the Middle District of North Carolina. He received his law degree from Wake Forest University School of Law, where he was a member of Moot Court and competed on the American Association for Justice trial team for two

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years. At graduation Patrick was selected by the law faculty for induction to the Order of the Barristers. Prior to law school, Patrick received his Bachelor of Arts degree from the University of Illinois at Urbana-Champaign in 2009, and his Associate in Arts degree from Heartland Community College in 2007. In 2019 and 2020, Patrick was named to the Super Lawyers’ Rising Stars list as one of the top young attorneys in North Carolina. Patrick is a member of the American Association for Justice and the North Carolina Association for Justice. Patrick maintains active involvement in his community through participating in his local church and in the Kiwanis Club of Raleigh.

Hunter Bryson Attorney

Hunter is an associate in Whitfield Bryson LLP’s litigation practice, with a focus on defective construction products and construction defect claims. He primarily focuses on representing owners who have been the unfortunate victims of poor manufacturing processes, as well as homeowners and commercial developers whose properties have been subjected to shoddy construction practices.

Hunter joined Whitfield Bryson LLP’s in 2016, after working as a law clerk for the firm, where he assisted in standing up for the rights of injured consumers on a daily basis.

Hunter earned his law degree from Campbell University School of Law in 2016. While at Campbell Law, he was elected as a justice to the honor court, a group leader for the peer mentor program, and a participant in the Campbell Law Connections program. Hunter earned his Bachelor of Arts degree from the University of North Carolina Chapel Hill, double majoring in Political Science and Economics. During the summer, Hunter interned for Themis Law Chambers in Cape Town, South Africa.

Harper T. Segui Senior Attorney

Harper T. Segui is an experienced litigator who focuses her practice on representing consumers in products liability litigation and other types of complex litigation across the country.

Harper attended the University of Central Florida where she obtained her Bachelor of Science before attending the Walter F. George School of Law at Mercer University. After graduating from law school in 2006, Harper practiced family law and general litigation in the Atlanta area for approximately a year before moving to Charleston, South Carolina.

Since moving to Charleston more than a decade ago, Harper’s primary focus has been representing plaintiffs in complex litigation and class actions, with a particular focus on product defects. Locally, she has contributed to millions of dollars in settlements and was an active trial lawyer in a case that resulted in a multi-million dollar jury verdict in favor of homeowners for a developer’s shoddy construction of townhomes in South Carolina. Nationally, she has several times been appointed by courts to serve on Plaintiffs’ Steering Committees, and has served as co-

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class counsel in several class actions. Likewise, Harper has enjoyed playing active roles in multidistrict litigation involving defective products. In the successful resolution of many of those cases, she contributed to millions of dollars in settlement money recovered for consumer.

Since 2013, Harper has been regularly selected to Super Lawyers as a Top-Rated Attorney in the areas of “Class Action & Mass Torts.” She has co-authored several publications on product liability cases, and has been a lecturer on complex legal issues. Harper is a member of the American Association for Justice and the Public Justice Foundation.

Drew Hathaway Attorney

As an attorney at Whitfield Bryson LLP, Drew Hathaway focuses on representing consumers in complex litigation. His primary focus is on product liability and consumer protection class actions both in the United States and internationally throughout Europe. Along with product liability cases, Drew currently represents the elderly in North Carolina’s first ever class action against an adult care home chain for understaffing their facilities. In addition to representing harmed consumers against some of the largest corporations in the world, Drew also represents commercial real estate owners in lawsuits related to defective construction.

Drew graduated from The University of North Carolina at Chapel Hill in 2003. While studying, he was a member of the varsity swim team at Chapel Hill. Drew earned his J.D. from Campbell University School of Law in 2007. While at Campbell, Drew was a member of the National Moot Court Team, inducted into the Order of Old Kivett and was an editor for the Campbell Law Observer.

Drew spent the first eight years of his career practicing as a defense lawyer with a primary focus on medical malpractice and commercial litigation. Drew has extensive trial experience and has received numerous honors as a trial attorney including recognition as North Carolina Super Lawyers Rising Stars, a peer selection for the top 2.5% of North Carolina Lawyers under the age of 40.

Since 2007, Drew has been on the board of directors for Vidas De Esperanza. Vidas is a 501(c)(3) non-profit that provides free health care and educational opportunities to the underserved in North Carolina and in Mexico. Drew is a member of the Public Justice Foundation, the American Association for Justice, the North Carolina Advocates for Justice, the Wake County Bar Association and the North Carolina Bar Association.

Erin Ruben Attorney

Erin Ruben focuses her practice on civil litigation, though she brings a wide range of experience in both civil and criminal law. Erin began her career in 2006 as a public defender with Virginia’s Indigent Defense Commission, where she represented the county’s most vulnerable defendants in criminal matters before judges and juries in the district and circuit courts of Fairfax

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County and in the Virginia Court of Appeals. After relocating to North Carolina in 2009, she began her civil litigation practice, primarily representing plaintiffs in medical malpractice, personal injury, and employment matters. From 2015-2017, she also owned and operated a small business with a retail location in Raleigh, NC, which provided her with a wealth of practical experience she has been able to apply to her practice. Erin is passionate about protecting and defending the rights and dignity of her clients through zealous, compassionate legal advocacy.

Erin earned her J.D. from Wake Forest University School of Law in 2006, where she was a member of the Moot Court Board. Erin obtained a Bachelor of Business Administration (B.B.A.) in Marketing from the University of Georgia in 2003, in addition to a Certificate in Personal and Organizational Leadership from UGA’s Institute for Leadership Advancement. While at UGA, Erin was honored to be named a Leonard Leadership Scholar, recognizing her academic achievement and demonstrated leadership.

Devon Landman Attorney

Devon Landman is an experienced litigator who focuses her practice on civil litigation, criminal defense, and personal injury. As a former prosecutor, Devon previously fought for those who have been wronged by crimes. She now diligently, meticulously, and vigorously fights for those who have been wronged by others’ negligence. She also passionately defends the rights of those accused of crimes and helps secure a fair outcome that allows them to move on with their lives.

Devon earned her undergraduate degree in Communications and Information Sciences from the University of Alabama in 2014. She earned her Juris Doctor degree from Belmont University College of Law in 2017. While in law school, Devon worked at both the Federal Public Defender’s Office in downtown Nashville and the State Attorney’s Office in the 18th Judicial Circuit in Viera, Florida.

After graduating law school, Devon joined the Florida Bar in September 2017. Upon licensure, she was an Assistant State Attorney for the State of Florida, prosecuting crimes on behalf of the State. During her time as an Assistant State Attorney, she served on the Board of Directors for the Brevard County Bar Association’s Young Lawyers Division.

In the summer of 2019, Devon moved back to Nashville and became licensed in the State of Tennessee. She is a member of the Tennessee Bar Association and its Young Lawyers Division, the Nashville Bar Association, the Tennessee Trial Lawyers Association, and Lawyers’ Association for Women – Marion Griffin Chapter. She is also a member of the American Association of Justice (AAJ).

Alex Straus Attorney

Alex R. Straus was born and raised in New York, NY. Alex is currently licensed to practice law in California, Massachusetts, New York, Rhode Island, and South Carolina. For more than a

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decade, he has represented consumers, labor unions, and municipalities throughout the United States in practice areas ranging from complex tort and personal injury to antitrust and securities litigation. Prior to joining Whitfield Bryson LLP, Alex spent the majority of his legal career as a litigation attorney with Motley Rice LLC after a long career as an investigative journalist and author. In 2013, Alex authored an amicus curiae brief filed in the Supreme Court of the United States in support of a shipyard worker who died as a result of asbestos exposure. An avid writer, Alex co-authored with legendary trial lawyer, Ron Motley, a chapter in the book Pathology of Asbestos-Related Diseases, which was published in 2014. Alex has also authored two books, Medical Marvels: The 100 Most Important Medical Advances (Prometheus Books, 2006) and Guerrilla Golf: The Complete Guide to Playing Golf on Mountains, Pastures, City Streets and Everywhere But the Course (Rodale Press, 2006). The author of more than 100 nationally published feature-length articles, Alex won the New York Press Association Best Sports Feature award in 1999. As a law student at Roger Williams University School of Law, Alex was the 2009 recipient of the Kathleen Brit Memorial Prize for Alternative Dispute Resolution and served as law clerk for the New England Patriots, working with the team’s General Counsel on real estate acquisitions, environmental compliance and collective bargaining issues. Alex attended Rollins College in Winter Park, Florida and Columbia University’s School of International and Public Affairs in New York, New York.

Notable Whitfield Bryson LLP Class Action Cases

Antitrust

In re: TFT-LCD (Flat Panel) Antitrust Litigation, No. 3:07-cv-01827, MDL No. 1827 (N.D. Cal.) (combined settlement totaling nearly $1.1 billion in suit alleging the illegal formation of an international cartel to restrict competition in the LCD panel market) (2012).

Appliances

Ersler, et. al v. Toshiba America et. al, No. 07- 2304 (D.N.J.) (settlement of claims arising from allegedly defective television lamps) (2009).

Maytag Neptune Washing Machines (class action settlement for owners of Maytag Neptune washing machines).

Stalcup, et al. v. Thomson, Inc. (Ill. Cir. Ct.) ($100 million class settlement of clams that certain GE, PROSCAN and RCA televisions may have been susceptible to temporary loss of audio when receiving broadcast data packages that were longer than reasonably anticipated or specified) (2004).

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Hurkes Harris Design Associates, Inc., et al. v. Fujitsu Computer Prods. of Am., Inc. (settlement provides $42.5 million to pay claims of all consumers and other end users who bought certain Fujitsu Desktop 3.5” IDE hard disk drives) (2003).

Turner v. General Electric Company, No. 2:05-cv-00186 (M.D. Fla.) (national settlement of claims arising from allegedly defective refrigerators) (2006).

Automobiles

In re General Motors Corp. Speedometer Prods. Liability Litig., MDL 1896 (W.D. Wash.) (national settlement for repairs and reimbursement of repair costs incurred in connection with defective speedometers) (2007).

Baugh v. The Goodyear Tire & Rubber Company (class settlement of claims that Goodyear sold defective tires that are prone to tread separation when operated at highway speeds; Goodyear agreed to provide a combination of both monetary and non-monetary consideration to the Settlement Class in the form of an Enhanced Warranty Program and Rebate Program) (2002).

Lubitz v. Daimler Chrysler Corp., No. L-4883-04 (Bergen Cty. Super. Ct, NJ 2006) (national settlement for repairs and reimbursement of repair costs incurred in connection with defective brake system; creation of $12 million fund; 7th largest judgment or settlement in New Jersey) (2007).

Berman et al. v. General Motors LLC, Case No. 2:18-cv-14371 (S.D. Fla.) (Co-Lead Counsel; national settlement for repairs and reimbursement of repair costs incurred in connection with Chevrolet Equinox excessive oil consumption).

Civil Rights

In re Black Farmers Discrimination Litigation, Case No. 1:08-mc-00511 (D.D.C.) ($1.25 billion settlement fund for black farmers who alleged U.S. Department of Agriculture discriminated against them by denying farm loans) (2013).

Bruce, et. al. v. County of Rensselaer et. al., Case No. 02-cv-0847 (N.D.N.Y.) (class settlement of claims that corrections officers and others employed at the Rensselaer County Jail (NY) engaged in the practice of illegally strip searching all individuals charged with only misdemeanors or minor offenses) (2004).

Commercial

In re: Outer Banks Power Outage Litigation, 4:17-cv-141 (E.D.N.C) (Co-Lead Counsel; $10.35 million settlement for residents, businesses, and vacationers on Hatteras and Ocracoke Islands who were impacted by a 9-day power outage) (2018)

Construction Materials

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Cordes et al v. IPEX, Inc., No. 08-cv-02220-CMA-BNB (D. Colo.) (class action arising out of defective brass fittings; court-appointed member of Plaintiffs’ Steering Committee) (2011).

Elliott et al v. KB Home North Carolina Inc. et al 08-cv-21190 (N.C. Super. Ct. Wake County) (Lead Counsel; class action settlement for those whose homes were constructed without a weather-resistant barrier)(2017)

In re: Pella Corporation Architect and Designer Series Windows Marketing, Sales Practices and Products Liability Litigation, MDL No. 2514 (D.S.C.)(class action arising from allegedly defective windows; Court-appointed Co-Lead Counsel).

In re MI Windows and Doors, Inc., Products Liability Litigation, MDL No. 2333 (D.S.C) (National class action settlement for homeowners who purchased defective windows; Court- appointed Co-Lead Counsel).

In re: Atlas Roofing Corporation Chalet Shingle Products Liability Litig., MDL No. 2495 (N.D. Ga.) (class action arising from allegedly defective shingles; Court-appointed Co-Lead Counsel).

Helmer et al. v. Goodyear Tire & Rubber Co., No. 12-cv-00685-RBJ (D. Colo. 2012) (class action arising from allegedly defective radiant heating systems; Colorado class certified, 2014 WL 3353264, July 9, 2014)).

In re: Zurn Pex Plumbing Products Liability Litigation, No. o:08-md-01958, MDL No. 1958 (D. Minn.) (class action arising from allegedly plumbing systems; member of Executive Committee; settlement) (2012).

Hobbie, et al. v. RCR Holdings II, LLC, et al., No. 10-1113 , MDL No. 2047 (E.D. La.) ($30 million settlement for remediation of 364 unit residential high-rise constructed with Chinese drywall) (2012).

In re: Chinese Manufactured Drywall Products Liability Litigation, No. 2:09-md-02047, MDL No. 2047 (E.D. La.) (litigation arising out of defective drywall) (appointed Co-Chair, Insurance Committee) (2012).

Galanti v. Goodyear Tire & Rubber Co., No. 03-209 (D.N.J. 2003) (national settlement and creation of $330 million fund for payment to owners of homes with defective radiant heating systems) (2003).

In re Synthetic Stucco Litig., Civ. Action No. 5:96-CV-287-BR(2) (E.D.N.C.) (member of Plaintiffs’ Steering Committee; settlements with four EIFS Manufacturers for North Carolina homeowners valued at more than $50 million).

In re Synthetic Stucco (EIFS) Prods. Liability Litig., MDL No. 1132 (E.D.N.C.) (represented over 100 individuals homeowners in lawsuits against homebuilders and EIFS manufacturers).

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Posey, et al. v. Dryvit Systems, Inc., Case No. 17,715-IV (Tenn. Cir. Ct) (Co-Lead Counsel; national class action settlement provided cash and repairs to more than 7,000 claimants) (2002).

Sutton, et al. v. The Federal Materials Company, Inc., et al, No. 07-CI-00007 (Ky. Cir. Ct) (Co- Lead Counsel; $10.1 million class settlement for owners of residential and commercial properties constructed with defective concrete).

Staton v. IMI South, et al. (Ky. Cir. Ct.) ((Co-Lead Counsel; class settlement for approximately $30 million for repair and purchase of houses built with defective concrete).

In re Elk Cross Timbers Decking Marketing, Sales Practices and Products Liability Litigation, No. 15-cv-0018, MDL No. 2577 (D.N.J.) (Lead Counsel; national settlement to homeowners who purchased defective GAF decking and railings).

Bridget Smith v. Floor and Decor Outlets of America, Inc., No. 1:15-cv-4316 (N.D. Ga.) (Co- Lead Counsel; National class action settlement for homeowners who purchased unsafe laminate wood flooring).

In re Lumber Liquidators Chinese-Manufactured Flooring Products Marketing, Sales Practices and Products Liability Litigation MDL No. 1:15-md-2627 (E.D.Va.) (Formaldehyde case; $36 million national class action settlement for member who purchased a certain type of laminate flooring).

In re Lumber Liquidators Chinese-Manufactured Laminate Flooring Durability Marketing, Sales Practices Litigation MDL No. 1:16-md-2743 (E.D.Va.) (Co-Lead Counsel; Durability case; $36 million national class action settlement for member who purchased a certain type of laminate flooring).

In re Windsor Wood Clad Window Products Liability Litigation MDL No. 2:16-md-02688 (E.D. Wis.) (National class action settlement for homeowners who purchased defective windows; Court-appointed Lead Counsel).

In re Allura Fiber Cement Siding Products Liability Litigation MDL No. 2:19-md-02886 (D.S.C.) (class action arising from allegedly defective cement board siding; Court-appointed Lead Counsel).

Environmental

Nnadili, et al. v. Chevron U.S.A., Inc, No. 02-cv-1620 (D.D.C.) ($6.2 million settlement for owners and residents of 200 properties located above underground plume of petroleum from former Chevron gas station) (2008).

In re Swanson Creek Oil Spill Litigation, No. 00-1429 (D. Md.) (Lead Counsel; $2.25 million settlement of litigation arising from largest oil spill in history of State of Maryland) (2001).

Fair Labor Standards Act/Wage and Hour

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Craig v. Rite Aid Corporation, Civil No. 08-2317 (M.D. Pa.) (FLSA collective action and class action settled for $20.9 million) (2013).

Stillman v. Staples, Inc., Civil No. 07-849 (D.N.J. 2009) (FLSA collective action, plaintiffs’ trial verdict for $2.5 million; national settlement approved for $42 million) (2010).

Lew v. Pizza Hut of Maryland, Inc., Civil No. CBB-09-CV-3162 (D. Md.) (FLSA collective action, statewide settlement for managers-in-training and assistant managers, providing recompense of 100% of lost wages) (2011).

Financial

Roberts v. Fleet Bank (R.I.), N.A., Civil Action No. 00-6142 (E. D. Pa.) ($4 million dollar settlement on claims that Fleet changed the interest rate on consumers’ credit cards which had been advertised as "fixed.") (2003).

Penobscot Indian Nation et al v United States Department of Housing and Urban Development, N. 07-1282 (PLF) (D.D.C. 2008) (represented charitable organization which successfully challenged regulation barring certain kinds of down-payment assistance; Court held that HUD’s promulgation of rule violated the Administrative Procedure Act) (2008).

Impact Fees

Town of Holly Springs, No. 17-cvs-6244, 17-cvs-6245, 18-cvs-1373 (Wake Co., NC) (Court appointed Class Counsel; Class action settlement with a $7.9 million fund for builders and developers to recover improper capacity replacement and transportation fees paid to the town) (2019).

Larry Shaheen v. City of Belmont, No. 17-cvs-394 (Gaston Co., NC) (Court appointed Class Counsel; Class action settlement with a $1.65 million fund for builders and developers to recover improper capacity replacement and transportation fees paid to the city) (2019).

Upright Builders Inc. et al. v. Town of Apex, No. 18-cvs-3720 & 18-cvs-4384, (Wake Co., NC) (Court appointed Class Counsel; Class action settlement with a $15.3 million fund for builders and developers to recover improper capacity replacement and transportation paid fees to the town) (2019).

Mayfair Partners, LLC et al. v. City of Asheville, No. 18-cvs-04870 (Buncombe County)(Court appointed Class Counsel; Class action settlement with a $1,850,000 million fund for builders and developers to recover improper impact fees paid to the city) (2020).

Shenandoah Homes, LLC v. Town of Clayton, No. 19-cvs-640 (Johnston County)(Court appointed Class Counsel; Class action settlement with a $2.7 million fund for builders and developers to recover improper impact fees paid to the town) (2020).

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Brookline Homes LLC v. City of Mount Holly, Gaston County file no. 19-cvs-1163 (Gaston County) (Court appointed Class Counsel; Class action settlement with a $483,468 fund for builders and developers to recover improper impact fees paid to the city) (2020).

Eastwood Construction, LLC et. al v. City of Monroe, Union County file nos. 18-CVS-2692 (Union County) (Court appointed Class Counsel; Class action settlement with a $1,750,000 million fund for builders and developers to recover improper impact fees paid to the city) (2020).

Insurance

Young, et al. v. Nationwide Mut. Ins. Co, et al., No. 11-5015 (E.D. Ky.) (series of class actions against multiple insurance companies arising from unlawful collection of local taxes on premium payments; class certified and affirmed on appeal, 693 F.3d 532 (6th Cir., 2012); settlements with all defendants for 100% refund of taxes collected) (2014).

Nichols v. Progressive Direct Insurance Co., et al., No. 2:06cv146 (E.D. Ky.) (Class Counsel; class action arising from unlawful taxation of insurance premiums; statewide settlement with Safe Auto Insurance Company and creation of $2 million Settlement Fund; statewide settlement with Hartford Insurance Company and tax refunds of $1.75 million ) (2012).

Privacy/Data Breach

In Re: U.S. Office of Personnel Management Data Security Breach Litigation, No. 15-1393 (ABJ), MDL No. 2664 (D.D.C.) (court appointed interim Liaison Counsel).

In re Google Buzz Privacy Litigation, No. 5:10-cv-00672 (N.D. Cal.) (court-appointed Lead Class Counsel; $8.5 million cy pres settlement) (2010).

In re: Dept. of Veterans Affairs (VA) Data Theft Litig., No. 1:2006-cv-00506, MDL 1796 (D.D.C.) (Co-Lead counsel representing veterans whose privacy rights had been compromised by the theft of an external hard drive containing personal information of approximately 26.6 million veterans and their spouses; creation of a $20 million fund for affected veterans and a cy pres award for two non-profit organizations) (2009).

In re: Adobe Systems Inc. Privacy Litigation, No. 5:13-cv-05226 (N.D. Cal. 2015) (settlement requiring enhanced cyber security measures and audits) (2015).

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Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust

Firm Name: Whitfield Bryson LLP Reporting Period: Inception

(1) Investigations & Factual Research (2) Discovery (3) Pleadings, Briefs & Legal Research (4) Court Appearances & Preparation

Historical Total Hourly Total Name Status Hours Rate Lodestar King, S. Austin A 28.5 375.00 $10,687.50 King, S. Austin A 5.6 300.00 $1,680.00 Wallace, Patrick A 1.3 375.00 $487.50 Wallace, Patrick A 0.5 300.00 $150.00 Ruben, Erin A 69.4 375.00 $26,025.00 Ruben, Erin A 110.4 300.00 $33,120.00

Hathaway, Andrew A 1.2 375.00 $450.00

TOTALS 216.9 $72,600.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 216 of 253 PageID# 11639

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Whitfield Bryson LLP Reporting Period: Inception through February 28, 2021

Disbursement Amount Electronic Research $20.10 Filing / Misc. Fees Overnight Delivery/Messengers $38.43 Photocopying Postage Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $831.08 Litigation Fund Contributions $15,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $15,889.61 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 217 of 253 PageID# 11640

Exhibit A-24 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 218 of 253 PageID# 11641

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF ROBERT A. BLAKE, JR. IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Robert A. Blake, Jr., hereby declare as follows:

1. I am a partner at the law firm of Wyatt & Blake, L.L.P. I submit this declaration in

support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement

of Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Wyatt & Blake, L.L.P. and its

attorneys are summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 135.7. The total lodestar for my firm is $75,100.00. My firm’s lodestar amount includes Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 219 of 253 PageID# 11642

only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit of the

Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the hourly

rates for my firm’s attorneys and professional staff are the same as the usual and customary hourly

rates charged by my firm for its services. The total attorney and professional staff time reflected

in this declaration is based on my firm’s contemporaneous, daily time records regularly prepared

and maintained by my firm, as well as any reductions in my firm’s lodestar required by Interim

Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $11,106.05 in

unreimbursed costs and expenses in this litigation through March 31 2021, including $10,000.00

in contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 220 of 253 PageID# 11643

Executed this 27th day of April 2021 in Charlotte, N01ih Carolina.

Robert A. Blake, Jr(/ Wyatt & Blake, L P NC State Bar No. 0858 435 E. Morehead Street Charlotte, NC 28202 (704) 331-0767 office (704) 331-0773 fax [email protected] Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 221 of 253 PageID# 11644

Exhibit A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 222 of 253 PageID# 11645

Exhibit A WYATT & BLAKE, LLP FIRM RESUME

The law firm of Wyatt & Blake, LLP engages in a litigation practice, and focuses

on white collar criminal investigations and prosecutions, whistleblower cases and class

action litigation. Wyatt & Blake maintain a peer rating of AV by Martindale Hubbell. In

addition, the firm has received a Tier I ranking by the national publication of Best Lawyers

“Best Law Firms”.

James F. Wyatt, III is recognized as one of North Carolina’s leading trial lawyers.

He is a member of the International Academy of Trial Lawyers, the American College of

Trial Lawyers, the Best Lawyers in America, has a Band 1 Ranking with Chambers and

Partners, and has been named on numerous occasions as the best white collar defense and

civil trial lawyer in both Charlotte and the State of North Carolina. James was recently

(2020) selected by Super Lawyers as the Number One Lawyer in North Carolina,

regardless of specialty or field.

James attended Vanderbilt University, graduating in 1978 with a degree in

Economics with highest honors. He graduated in 3 ½ years, was the Salutatorian of his

graduating class, and was a member of Phi Beta Kappa and many other honorary

societies. James obtained his Certified Public Accountant (CPA) certificate after

graduating from college. James graduated from Duke Law School in 1982, after being

selected by his peers as the Executive Editor of the Duke Law Journal and as the Chairman

of the Moot Court Board.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 223 of 253 PageID# 11646

After graduating from Duke Law School, James clerked for United States District

Court Judge Harold L. Murphy in the Northern District of Georgia.

James is listed in Best Lawyers in America in four separate categories:

Bet-The-Company Litigation, Commercial Litigation, Non-White Collar Criminal Defense

and White Collar Criminal Defense. He is also a Member of the American College of Trial

Lawyers, an organization consisting of outstanding civil and criminal trial lawyers (with

fewer than 1% of the lawyers in the United States and Canada becoming members of this

organization after a thorough vetting process). Additionally, James was inducted into the

International Academy of Trial Lawyers, whose membership is limited to 500 fellows from

the United States “who have achieved a career of excellence through demonstrated skill

and ability in jury trials.”

Robert A. Blake, Jr. has been a partner at Wyatt & Blake for more than 15 years.

Rob’s legal career began as a law clerk for United States District Court Judge Graham C.

Mullen (Western District of North Carolina), followed by a clerkship with The Honorable

Wade Brorby (United States Court of Appeals for the Tenth Circuit). Rob engages in a

litigation practice in which he represents individuals and businesses in white collar criminal

investigations, federal criminal cases, qui tam cases, class action litigation, and other

complex civil litigation. Rob has received a peer review rating of AV Preeminent from

Martindale Hubbell in the categories of White Collar Crime, Criminal Law and Litigation.

Rob Blake attended the University of North Carolina-Chapel Hill as an

undergraduate, where he pursued a double major in criminal justice and psychology. He

graduated with honors in 1991.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 224 of 253 PageID# 11647

Thereafter, Rob attended law school at Wake Forest University, where he was a

member of the Scholastics Honor Society, an Editorial Board Member of the Wake Forest

Law Review, and a legal research and writing teaching assistant. Rob graduated cum laude

from Wake Forest Law School in 1994.

Rob is admitted to practice law in North Carolina and in the United States District

Courts for the Western, Middle and Eastern Districts of North Carolina, and the United

States Court of Appeals for the Fourth Circuit and the United States Court of Appeals for

the Tenth Circuit.

Wyatt & Blake has represented plaintiffs and defendants in class action litigation

filed in both federal and state courts. For example, in Nicholson v. F. Hoffman-Laroche,

Ltd., Wyatt & Blake were co-counsel for a class of plaintiffs suing vitamin

manufacturers. A class action settlement of more than $225 million was achieved in this

case on behalf of the plaintiff class. Wyatt & Blake also served as counsel for the North

Carolina class of purchasers of liquid crystal display (LCD) televisions and computer

monitors. A nationwide settlement of approximately $1.1 billion was negotiated with the

defendants in that case. This was the largest antitrust class action settlement in the United

States.

Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 225 of 253 PageID# 11648

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust

Firm Name: Wyatt & Blake, L.L.P. Reporting Period: Inception through February 28, 2021

Historical Total Hourly Total Name Status Hours Rate Lodestar Wyatt, James P 7.9 700.00 $5,530.00 Blake, Rob P 112 600.00 $67,200.00 Wooten, Ginny PL 13.7 150.00 $2,055.00 Ashley Burnett PL 0.8 150.00 $120.00 Nikki Garrity PL 1.3 150.00 $195.00

TOTALS 135.7 $75,100.00

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 226 of 253 PageID# 11649

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Wyatt & Blake, L.L.P. Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $722.50 Filing / Misc. Fees Overnight Delivery/Messengers Photocopying $357.05 Postage $1.50 Service of Process Fees Telephone / Fax Transportation / Meals / Lodging $25.00 Litigation Fund Contributions $10,000.00 Expert Fees Secretarial OT / Word Processing Court Reporter Service/Transcript Fees Microfilm / Video / Disks Duplication TOTAL $11,106.05 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 227 of 253 PageID# 11650

Exhibit A-25 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 228 of 253 PageID# 11651

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF CHRISTOPHER T. MICHELETTI IN SUPPORT OF INDIRECT PURCHASER PLAINTIFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, Christopher T. Micheletti, hereby declare as follows:

1. I am a partner at the law firm of Zelle LLP. I submit this declaration in support of

Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement of

Expenses, and Service Awards to the Class Representatives.

2. I have personal knowledge of the matters stated herein, and if called upon, I could

and would competently testify thereto.

3. My firm has acted as counsel for Indirect Purchaser Plaintiffs in this litigation on

an entirely contingent basis. The background and experience of Zelle LLP and its attorneys are

summarized in the firm resume attached hereto as Exhibit A.

4. The schedule attached as Exhibit B sets forth my firm’s total hours and attorneys’

fee lodestar in this litigation for work performed at the direction of Interim Co-Lead Counsel. This

includes work performed by my firm’s attorneys and professional staff, computed at my firm’s

historical hourly rates, through February 28, 2021.

5. The total number of hours expended in this litigation by my firm through February

28, 2021 is 765.2. The total lodestar for my firm is $515,945.50. My firm’s lodestar amount

1 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 229 of 253 PageID# 11652

includes only work assigned by Interim Co-Lead Counsel and performed by my firm for the benefit

of the Indirect Purchaser Plaintiffs. Unless otherwise capped by Interim Co-Lead Counsel, the

hourly rates for my firm’s attorneys and professional staff are the same as the usual and customary

hourly rates charged by my firm for its services. The total attorney and professional staff time

reflected in this declaration is based on my firm’s contemporaneous, daily time records regularly

prepared and maintained by my firm, as well as any reductions in my firm’s lodestar required by

Interim Co-Lead Counsel.

6. My firm complied with the instructions provided by Interim Co-Lead Counsel that

set forth the guidelines for the categories of work and hourly rates permitted to be included in this

declaration. All of the services performed by my firm in connection with this litigation were

reasonably necessary in the prosecution of this case. There has been no unnecessary duplication

of services for which my firm now seeks compensation.

7. As detailed in Exhibit C, my firm has incurred a total of $42,965.61 in

unreimbursed costs and expenses in this litigation through March 31, 2021, including $40,000 in

contributions to the Indirect Purchaser Plaintiffs’ joint litigation fund. My firm advanced these

costs and expenses with no assurance that such costs and expenses would be repaid. My firm has

only set forth costs and expenses incurred through March 31, 2021, in accordance with the

guidelines established by Interim Co-Lead Counsel.

8. The costs and expenses incurred in this action are reflected on the books and records

of my firm. These books and records are prepared from expense vouchers, check records, and other

source materials and represent an accurate record of the costs and expenses incurred. These

expenses were reasonably and necessarily incurred in connection with this litigation.

9. I declare under penalty of perjury that the foregoing is true and correct.

2 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 230 of 253 PageID# 11653

Executed this 29th day of April 2021 in Truckee, California.

Christopher T. Micheletti

3 Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 231 of 253 PageID# 11654

EXHIBIT A Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 232 of 253 PageID# 11655 ZELLELLP

Firm Resume Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 233 of 253 PageID# 11656 ZELLELLP

Firm Overview

Zelle attorneys represent clients in their most challenging insurance-related disputes, antitrust/competition and other complex business litigation in venues across the United States and around the world. Our experience in successfully resolving high-profile, high-exposure cases and our commitment to efficient and responsive service supports everything we do.

Because we represent both defendants and plaintiffs, our attorneys have developed keen insights and experience from practicing on both sides of the aisle. We can better understand and anticipate the objectives and tactics of opposing counsel, giving our clients a number of distinct advantages. Since our contingency practice obligates us to fund many of our clients' cases, we are particularly adept in avoiding unnecessary tasks and expenses while doing everything to achieve the most favorable outcomes. Our clients appreciate this ability to efficiently staff cases while still delivering exceptional service and consistent results.

We believe – and our clients agree – that the way we approach litigation is key to our success in building solid relationships and implementing effective strategies. Our attorneys offer experience and in-depth knowledge across a wide range of industries, and probe to determine our clients’ specific needs and the broader implications of any dispute. Zelle attorneys quickly assess the facts, balance the intangibles, and deliver legal counsel that is creative and realistic.

While the scope of our practice is focused, the diverse talents, intellectual knowledge and technological resources we offer are vast. Zelle’s collaborative teams of attorneys, multiple offices and international presence assure that we are always prepared to meet your needs, even in the most challenging, sensitive or catastrophic of circumstances.

PRACTICE CONTACTS Our approach to antitrust matters is decidedly different from other firms because we commonly represent clients – multi-national corporations, small James Robertson Martin businesses and consumers – on either side of the docket. We are selective in Judith A. Zahid the litigation we pursue and consistently position that litigation for success in the courtroom. We have found this approach yields the best results for our clients, whether at the settlement table or at trial. We carefully consider the objectives and economic realities of each client, looking for the best way to achieve an outcome that meets those needs. We are a diverse group (two thirds women and/or of color) of skilled attorneys who elevate our performance through our collaborative approach with our colleagues and clients.

The experience and track record of Zelle attorneys in antitrust is recognized in courts across the nation every day. We have recovered billions of dollars for our clients who are plaintiffs, and we have successfully mitigated other clients’ most significant exposures. We have substantial experience not just settling antitrust matters, but trying them. Martindale-Hubbell consistently ranks Zelle as one of the most active antitrust firms in the United States. Our lawyers are often named to lead counsel positions in class action and multi-district matters, but we are also highly effective in representing antitrust defendants and opt-out plaintiffs.

Zelle recognizes that many antitrust matters are increasingly international in scope. We routinely work with clients and foreign counsel in the United Kingdom, European Union, Canada and China to coordinate and fully protect our clients’ legal and business interests in a global context.

Because of the breadth and depth of our litigation experience, clients often call on us in counseling situations – including consultation on antitrust compliance programs, mergers and acquisitions, and the formation of joint ventures.

PRACTICE CONTACTS Zelle is among the preeminent antitrust class action litigation firms in the United States with class action litigators in Oakland, Washington DC and Minneapolis. Christopher T. Micheletti With many decades of collective experience, Zelle attorneys have successfully Judith A. Zahid represented classes of consumers and businesses in California, multi-state and nationwide antitrust class actions. We have also successfully defended corporations in antitrust class actions. We are a diverse group (two thirds women and/or of color) of skilled attorneys who elevate our performance through our collaborative approach with our colleagues and clients.

Given our focus and success in this area, Zelle and its antitrust litigators have garnered numerous antitrust class action and other antitrust accolades, including repeated top tier and other recognition by The Legal 500, U.S. News – Best Lawyers in America, Chambers & Partners USA, Super Lawyers, Global Competition Review’s Who’s Who Legal and Rising Stars, Lawdragon and the Daily Journal.

Zelle is particularly well-known for its representation of classes of indirect purchaser plaintiffs (consumers and other end purchasers of affected products from cartelists), and direct purchaser plaintiffs (business entities that directly purchase such products from cartelists). Zelle has an unparalleled record of leading and contributing to successes on behalf of both indirect purchaser and direct purchaser classes.

Zelle attorneys have been appointed by courts as lead counsel, co-lead counsel, liaison counsel, or as members of executive committees in numerous antitrust class actions, and are frequently relied upon to make critical contributions to case prosecution and success as co-counsel in non-leadership positions.

REPRESENTATIVE MATTERS

In re: Hard Disk Drive Suspension Assemblies Antitrust Litigation, 19-md-02918-MMC. Co-Lead counsel for indirect purchaser end-user plaintiffs.

In re California Gasoline Spot Market Antitrust Litigation, No. 3:20-cv-03131-JSC. Member, Executive Committee, and Liaison to the California Attorney General’s Ofﬁce, representing gasoline buyers throughout the state of California.

German Automotive Manufacturers Antitrust Litigation, 3:17-md-02796-CRB (N.D. Cal.). Member, Plaintiff’s Steering Committee, representing direct purchasers of German automobiles.

In re: Railway Industry Employee No-Poach Antitrust Litigation, MDL No. 2850. Counsel for railway industry employee settlement class and settlement class representative, with case settlements of $49 million.

Lithium Ion Batteries Antitrust Litigation, MDL No. 2420 (N.D. Cal.). Liaison Counsel for direct purchaser plaintiffs and signiﬁcant responsibilities for industry experts, with case settlements totaling almost $140 million.

Brown v. 140 NM LLC, et al., No. 4:17-cv-05782-JSW. Defended several Bay Area restaurants accused of engaging in a nationwide no-tipping conspiracy to drive up prices, helping get the case dismissed with prejudice.

In Re: Domestic Airline Travel Antitrust Litigation, 1:15-mc- 01404-CKK (D. D.C.). Counsel for direct purchaser plaintiffs with signiﬁcant responsibilities in defendant discovery and related matters.

In Re: Packaged Seafood Products Antitrust Litigation, 3:15- md-02670-JLS-MDD (S.D. Cal.). Counsel for indirect purchaser end payor plaintiffs with signiﬁcant responsibilities in pleading, expert work and class certiﬁcation efforts.

In re Automotive Parts Antitrust Litigation, MDL No. 2311, No. 12-md-02311 (E.D. Mich.). Member, Plaintiffs’ Executive Committee for indirect purchaser end payor plaintiffs, with case settlements of over $1 billion.

In re TFT-LCD (Flat Panel) Antitrust Litigation, MDL No. 07- 1827 (N.D. Cal.). Co-Lead Counsel for 23 litigated indirect purchaser end payor state damages classes with case settlements totaling $1.1 billion.

In re SRAM Antitrust Litigation, MDL No. 07-1819 (N.D. Cal.). Lead Counsel for 25 litigated indirect purchaser end-payor classes with case settlements totaling $41.3 million.

In re Cathode Ray Tubes (CRT) Antitrust Litig., MDL NO. 1917 (N.D. Cal.). Counsel for 22 litigated indirect purchaser end payor state damages classes with case settlements totaling $580 million, and with central role in obtaining class certiﬁcation, expert work, trial preparation, and other case matters.

In re Dynamic Random Access Memory (DRAM) Antitrust Litig., MDL No. 1486 (N.D. Cal.). Liaison Counsel for indirect purchaser end payor classes with case settlements of over $310 million.

Sullivan et al. v. DB Investments, Inc. et al., (DeBeers Diamonds Antitrust Litigation), Civil No. 04-02819 (SRC) (D. N.J.). Court-appointed class counsel for indirect purchaser end payor classes with case settlements of $295 million.

Microsoft Antitrust Litigation - California Microsoft Cases, J.C.C.P. No. 4106 (Cal. Super. Ct., San Francisco Cty.); Microsoft Antitrust Litigation, No. 00-5994 (Minn. Dist. Ct., Hennepin Cty.); Comes v. Microsoft Corp., No. CL 82311 Co-Lead Counsel, Liaison Counsel and/or Member, Executive Committee in these indirect-purchaser class

Smokeless Tobacco Antitrust Litigation, J.C.C.P. Nos. 4250, 4258, 4259 & 4262 (California Superior Court, San Francisco). Member, Plaintiffs’ Executive Committee, representing California indirect purchasers of canned smokeless tobacco products with case settlement of $96 million for the California class.

In re Flash Memory Antitrust Litigation, MDL No. 1852 (N.D. Cal.). Co-Lead Counsel for indirect purchasers.

In re Intel Corp. Microprocessor Antitrust Litigation, MDL No. 1717 (D. Del.). Liaison Counsel and Member, Executive Committee, representing indirect purchasers.

In re Graphics Processing Units Antitrust Litigation, MDL 1826 WHA (N.D. Cal.). Co-Lead Counsel for indirect purchasers.

California Natural Gas Antitrust Litigation, J.C.C.P. Nos. 4221, 4224, 4226 & 4228 (Cal. Superior Court, San Diego). Member, Executive Committee, representing indirect purchasers of natural gas in California, with case settlements totaling nearly $165 million.

Christopher T. Micheletti Partner

Chris is a commercial litigator with extensive experience in the areas of antitrust, business litigation, intellectual property, unfair competition and class actions. In the antitrust area, Chris has represented individuals and businesses in class action litigation, and has advised, represented and defended corporate clients in individual actions. Chris has played central roles in the successful prosecution of California state and nationwide antitrust class actions. In recognizing Zelle as one of the nation’s top plaintiffs’ antitrust firms, The Legal 500 has described Chris as a “determined and highly skilled litigator.”

555 12th Street In the intellectual property area, Chris has extensive experience in all aspects Suite 1230 Oakland, CA 94607 of trademark, trade dress and trade secrets litigation, representing both TEL: (415) 633-1912 plaintiffs and defendants. Chris’ business litigation practice has included FAX: (415) 693-0770 representation of plaintiffs and defendants in cases involving business torts, [email protected] contractual disputes, false advertising, fiduciary matters, libel, slander and PRACTICE AREAS unfair business practices. Chris also has significant experience handling complex property insurance litigation involving a wide variety of coverage, Antitrust and Unfair Competition repair and other issues. Breach of Contract REPRESENTATIVE MATTERS Class Actions Commercial Litigation In re Cathode Ray Tubes (CRT) Antitrust Litigation (class action on behalf of Corporate Plaintiff indirect purchasers of CRTs in multiple states; case settled for $576,750,000; Affirmative Recovery Chris played a central role in briefing and arguing class certification resulting Financial Services Litigation Indirect and Direct in certification of 22 state-wide damages classes) Purchaser Class Actions In re Static Random Access Memory (SRAM) Antitrust Litigation (class action Property Insurance on behalf of indirect purchasers of SRAM in multiple states; Zelle was lead BAR AND COURT ADMISSIONS counsel and Chris led the plaintiffs’ team in the litigation of this complex, State Court: California price-fixing action, resulting in settlements of $41,322,000) U.S. Circuit Court of Appeals: Sixth, Seventh and California Smokeless Tobacco Antitrust Litigation ($96,000,000 settlement on Ninth Circuits behalf of a class of California indirect purchasers of moist smokeless tobacco U.S. District Court: Northern products; as a member of the Plaintiffs’ Executive Committee, Chris had a District of California; Central central role in litigating and settling this monopolization claim on behalf of the District of California class) EDUCATION

Christopher T. Micheletti

University of California at Kellogg Co. v. Exxon Mobil Corp. (trademark infringement and dilution action Berkeley, B.A., 1983 under the Lanham Act, alleging that Exxon's use of its cartoon tiger to promote foods, beverages and convenience stores infringed and diluted Kellogg's famous TONY THE TIGER character)

Adco Group et al. v. Travelers et al. (complex coverage action involving the coordination of multiple lawsuits with over 25 parties, claims of $250 million in construction defects and damage at a luxury resort in Southern California)

ARTICLES & PRESENTATIONS

Antitrust and Class Actions

"Indirect Purchaser Antitrust Standing Heads In New Direction," Competition Law360, July 2, 2020, co-author

"Indirect Purchaser Cases in 2017: Key District Court Rulings," Competition Law360, January 8, 2018, co-author

"Indirect Purchaser Cases in 2017: Key Appeals Court Rulings," Competition Law360, January 5, 2018, co-author

“False Advertising Class Actions: Practitioner’s Guide to Class Certification, Damages and Trial,” Bar Association of San Francisco seminar, June 14, 2017, moderator

"2016 Highlights From Indirect Purchaser Class Actions," Competition Law360, December 23, 2016, co-author

ABA Section of Antitrust Law, Indirect Purchaser Litigation Handbook, Second Edition (2016), contributing author

"2 Years After Comcast, Little Has Changed," Competition Law360, March 18, 2015, co-author

“The California Difference: Why California Really Matters – A Symposium – Indirect Purchaser Standing Under California Antitrust Law and Federal Antitrust Law – Plaintiff Perspective,” The Journal of the Antitrust and Unfair Competition Law Section of the State Bar of California, Competition Vol. 22, No. 2, Fall 2013, author

Christopher T. Micheletti

"Incentive Award Guidance From Recent Class Actions," Competition Law360, September 6, 2013, co-author

Class Actions and Other Aggregate Litigation - New Supreme Court Cases on Evidentiary Standards: When do Plaintiffs Need to Prove What, and How Do They Need to Do That? Law Seminars International 9th Annual Conference, Seattle, WA, May 13, 2013, co-panelist

"Indirect-Purchaser Exceptions To Illinois Brick Continue," Competition Law360, January 25, 2013, co-author

"Why Class Counsel Should Obtain Discovery From Objectors," Competition Law360, November 6, 2012, co-author

"Coordinating Direct And Indirect Purchaser Cases," Competition Law360, July 9, 2012, co-author

"Emerging Trends In Indirect-Purchaser Antitrust Cases," Competition Law360, January 20, 2012, co-author

Intellectual Property, Unfair Competition and False Advertising

Food Labeling and False Advertising Class Actions panel presentation, Bar Association of San Francisco - Continuing Legal Education, San Francisco, CA, May 13, 2015, moderator

"In Search of BIGFOOT: Corrective Advertising Remedies in U.S. Trademark Infringement Actions—Part 2," INTA Bulletin, January 15, 2015, author

"In Search of BIGFOOT: Corrective Advertising Remedies in U.S. Trademark Infringement Actions—Part 1," INTA Bulletin, January 1, 2015, author

Food Labeling and False Advertising Class Actions panel presentation, Bar Association of San Francisco - Continuing Legal Education, San Francisco, CA, May 14, 2014, moderator

Trademark Protection: Best practices for trademark selection, use, maintenance and protection, Law Seminars International Telebriefing, March 6, 2013, moderator and presenter

Christopher T. Micheletti

"False Advertising: Skinny Girl Wriggles Free, While Pom and Arizona Beverages Fizzle," Supermarket News - Refresh Blog, February 5, 2013, co-author

PROFESSIONAL AFFILIATIONS

Bar Association of San Francisco

- Antitrust and Litigation Section

- Intellectual Property Section

American Bar Association

- Antitrust Law Section

Committee to Support the Antitrust Laws (COSAL), Member, Executive Committee

Member, Executive Committee of the Litigation Section of the Bar Association of San Francisco, 2014-2017

Member, International Trademark Association Bulletin Committee, Features Subcommittee 2014-2015

Member, Editorial Board of the International Trademark Association’s Trademark Reporter Committee, 2002-2007 and 2010-2013

COMMUNITY SERVICE

Legal Aid At Work, Member, Board of Directors, 2011-present; Member, Development Committee, 2013 - present

NOTEWORTHY

Selected for inclusion in the 2014 - 2021 editions of The Best Lawyers in America®.

Selected for inclusion in Who’s Who Legal: Competition among attorneys specializing in representing plaintiffs in complex competition litigation in 2019 and 2020.

Christopher T. Micheletti

Named a Northern California "Super Lawyer" in Antitrust, Business and/or Intellectual Property Litigation in 2004, 2005, 2010, 2014, 2015, 2016, 2017, 2018, 2019 and 2020.

Named a “California Litigation Star” in Antitrust and General Commercial litigation for 2019 - 2021 in Benchmark Litigation.

Recognized as a “pragmatic . . , determined and highly skilled litigator” in The Legal 500.

Named among the 2019 and 2020 Lawdragon "500 Leading Plaintiff Financial Lawyers."

Named among Daily Journal’s 2020 list of ‘Top Antitrust Lawyers’ in California.

NEWS

Zelle Attorneys Recognized as Benchmark Litigation Stars for 2021

PAST PROFESSIONAL EXPERIENCE

Furth, Fahrner & Mason, San Francisco, 1988-2000

Qianwei Fu Partner

Qianwei has handled a wide variety of litigation matters, with an emphasis on representing consumers and opt-out claimants in antitrust cartel and monopolization cases. Her antitrust experience covers a wide array of industries such as energy, automotive, transportation, and technology. Qianwei has played a primary role in all critical stages of litigation in some of the nation’s largest antitrust cases. She routinely works with economic and industry experts on damages and pass-on issues. Qianwei also has expertise in assessing and pursuing antitrust claims with international components and has collaborated with co-counsel in Canada, China and Europe to obtain

555 12th Street recovery for multinational corporations. Her international background and Suite 1230 training give her the broad scope and a sophisticated mix of skills necessary to Oakland, CA 94607 navigate the unique legal and practical challenges that arise in cross-border TEL: (415) 633-1906 antitrust disputes. In addition to her antitrust practice, Qianwei specializes in FAX: (415) 693-0770 [email protected] complex commercial litigation and insurance class action defense.

PRACTICE AREAS REPRESENTATIVE MATTERS

Antitrust and Unfair Antitrust and Unfair Competition Competition Commercial Litigation Represented end users in the Cathode Ray Tube antitrust litigation and Class Actions worked closely with lead counsel on case discovery, management, prosecution Antitrust Counseling & and settlement strategies, resulting in a $576.8 million cash settlement (In re: Compliance Cathode Ray Tube (CRT) Antitrust Litig., No. C-07-5944-SC (N.D. Cal.)). Breach of Contract Corporate Plaintiff Represented direct purchasers of lithium-ion batteries and assisted co-lead Affirmative Recovery counsel by managing document review on critical elements of proof and by eDiscovery holding primary responsibility for industry expert’s discovery and Daubert Indirect and Direct Purchaser Class Actions briefing. The case settled for nearly $140 million in cash (In re Lithium Ion International Competition Batteries Antitrust Litigation, No. 13-md-02420 YGR (N.D Cal.)). Pandemic Claims and Litigation Played a primary role in key aspects of the TFT-LCD antitrust litigation as part Products Liability of the core team that represented consumer class members, which resulted in a record-breaking $1.082 billion all-cash settlement (In re TFT-LCD (Flat BAR AND COURT ADMISSIONS Panel) Antitrust Litig., No. M 07-1827 SI (N.D. Cal.)). State Court: California U.S. Circuit Court of Represented indirect purchasers of rough and polished diamonds against De Appeals: Ninth Circuit Beers for fixing diamond wholesale prices, which resulted in a $295 million U.S. District Court: Northern cash settlement (Sullivan v. DB Investments, Inc., 667 F.3d 273 (3d Cir. 2011), District of California cert. denied, 132 S. Ct. 1876 (U.S. 2012)). Chinese Bar

Qianwei Fu

EDUCATION Represented consumer class members in the Static Random Access Memory U.C. Davis, School of Law, antitrust litigation as part of the lead counsel team, resulting in settlements of J.D., 2005; Articles Editor, $41.3 million (In re: Static Random Access Memory (SRAM) Antitrust Litig., U.C. Davis Law Review No. C 07-01819 CW (N.D. Cal.)). University of Maryland, M.A. in Criminology and Criminal Business & Commercial Disputes Justice, 2002 Xiamen University, School of Currently represents property insurers in multi-state class action coverage Law, China, LL.B. (with disputes arising from COVID-19. honor), 1996 Advised a multinational food company in an antitrust recovery action on litigation and settlement strategies in the European Union.

Represented a multinational energy corporation in an environmental dispute involving remediation cost allocation and obtained favorable result in arbitration.

Consulted on cash-out settlement strategies in a dispute involving environmental remediation liabilities between two multinational energy companies.

ARTICLES & PRESENTATIONS

Competition, The Journal of the Antitrust, UCL and Privacy Section of the California Lawyers Association, Vol. 30, Nos. 1-2 (2020), Editor-in-Chief

California State Antitrust & Unfair Competition Law (Matthew Bender 2019), Editor-in-Chief and co-author

“Demystifying the Mystery: China-related Disputes and Investigations Update”, California Lawyers Association, May 17, 2019, presenter

“Look Back, Look Forward: China’s Anti-Monopoly Law Enforcement”, California Lawyers Association, July 25, 2018, moderator

“Has the Clock Run? – Tolling Rules in Private Antitrust Litigation in the US, EU, and China”, American Bar Association, June 28, 2018, presenter

Qianwei Fu

“Judges Panel: Managing Antitrust and Complex Business Trials”, 27th Annual Golden State Antitrust, UCL and Privacy Law Institute, October 2017, moderator

“Private Antitrust Actions in China: Statute of Limitations”, ABA Antitrust Section Global Private Litigation Bulletin, July 2017, co-author

“Understanding and Navigating Cross-Border Privilege Issues”, State Bar of California, May 18, 2017, presenter

“Cross-Border Discovery – A Big Chess Game?”, American Bar Association, April 27, 2017, panelist

“Discovery in International Antitrust Litigation – How to Cross the Border?”, State Bar of California, March 30, 2016, panelist

ABA Section of Antitrust Law, Indirect Purchaser Litigation Handbook, Second Edition (2016), contributing author

“Insurance Chain Reaction from the Tianjin Port Explosion,” Insurance Law360, September 29, 2015, author

“A Primer on Insurance Dispute Resolution in China,” Insurance Law360, July 14, 2015, co-author

“A Primer on Insurance Underwriting in China,” Insurance Law360, June 10, 2015, co-author

“Thinking Globally about Recovery Actions in International Cartel Cases,” Journal of Antitrust Enforcement, 3, 363-390 (Oxford University Press 2015), co-author

“Finding Peace When Settling U.S. and EU Price-Fixing Claims,” Competition Law360, April 28, 2014, co-author

“Recent Developments: CAFA, Class Certification, and Class Arbitration,” paper for the Second Annual Judicial Education Conference, Dana Point, California, March 16-18, 2014, co-author

“Where to Bring Damages Claims in EU Int’l Cartel Cases?” Competition Law360, February 28, 2014, co-author

Qianwei Fu

“International Cooperation in Private Antitrust Litigation,” paper for the 10th International Cartel Workshop, Rome, Italy, February 19-21, 2014, co-author

“Unique Discovery Challenges in International Cartel Cases,” Competition Law360, January 31, 2014, co-author

“Ongoing Tension between Filed-Rate and State-Action Doctrines,” Competition Law360, July 10, 2013, co-author

PROFESSIONAL AFFILIATIONS

American Bar Association, Antitrust Section

California Lawyers Association Antitrust and Unfair Competition Law Section Executive Committee, Chair (2020-2021), Vice Chair (2016-2020)

All China Lawyers Association

NOTEWORTHY

Recognized as a “Next Generation Lawyer” by Legal 500 in 2019 and 2020

Named among the 2019 and 2020 Lawdragon “500 Leading Plaintiff Financial Lawyers”

Named a Northern California “Rising Star” in 2011–2016 and “Super Lawyer” in 2017-2020

A member of the core litigation team in TFT-LCD that received the 2013 AAI Honorable Mention for Outstanding Antitrust Litigation Achievement in Private Law Practice

NEWS

Qianwei Fu Appointed Chair of the CLA Antitrust, UCL and Privacy Section Executive Committee

Heather T. Rankie Counsel

Heather’s practice is devoted to complex civil litigation, with a focus on recovery for class plaintiffs and corporate clients who are victims of antitrust and unfair competition violations. Heather has played a vital role in some of the nation’s largest antitrust class cases, from pre-complaint investigation through litigation and resolution, and is particularly adept at addressing challenging discovery, damages, and pass-on issues. She has also briefed and argued complex issues at the appellate level. Heather brings a steadfast commitment to achieving the best result for each client, and attention to the details vital to successful resolutions of high stakes matters.

555 12th Street Heather is active in bar association leadership at both the national and local Suite 1230 Oakland, CA 94607 level, including with the ABA Antitrust Section. TEL: (415) 633-1917 FAX: (415) 693-0770 REPRESENTATIVE MATTERS [email protected] TFT-LCD (Flat Panel) Antitrust Litigation (U.S. District Court, Northern District PRACTICE AREAS of California) — lead counsel team in multidistrict litigation on behalf of Antitrust and Unfair nationwide class of indirect purchasers involving claims of price fixing in the Competition TFT-LCD panel market, resulting in a record-breaking $1.1 billion in all-cash Class Actions settlements with ten defendants Corporate Plaintiff Affirmative Recovery Lithium Ion Batteries Antitrust Litigation (U.S. District Court, Northern District Financial Services Litigation of California) — liaison counsel team in multidistrict litigation on behalf of Indirect and Direct nationwide class of direct purchasers involving claims of price fixing in the Purchaser Class Actions lithium ion battery market International Competition

BAR AND COURT ADMISSIONS Credit/Debit Card Tying Cases (California Superior Court, San Francisco) — lead counsel team in coordinated class action lawsuit on behalf of California State Court: California consumers involving antitrust and unfair competition claims arising from the U.S. District Court: Northern defendants' rules regarding acceptance of their credit and debit cards District of California U.S. Court of Appeals: Ninth Transpacific Air Passenger Antitrust Litigation (U.S. District Court, Northern Circuit District of California) — litigation team in multidistrict litigation on behalf of a EDUCATION nationwide putative class involving claims of price fixing in the transpacific air University of Washington passenger market School of Law, J.D., 2009; Editor-in-Chief, Shidler Journal of Law, Commerce & Technology Middlebury College, B.A., cum laude, 2003 ATLANTA | BOSTON | DALLAS | LONDON | MIAMI | MINNEAPOLIS NEW YORK | OAKLAND | PHILADELPHIA | WASHINGTON, DC Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 249 of 253 PageID# 11672

Heather T. Rankie

PUBLICATIONS & PRESENTATIONS

"The Fix Is In! How to Investigate and Litigate Price Fixing Cases,” American Bar Association, December 8, 2020, panelist

PROFESSIONAL AFFILIATIONS

Vice Chair, American Bar Association, Antitrust Section, Competition Torts Committee (2019–present)

Executive Committee, Bar Association of San Francisco, Antitrust and Business Regulation Section (2017–present)

Steering Committee, Bar Association of San Francisco, Wellness 2020 Initiative (2019–2020)

PRO BONO ACTIVITIES

Heather represents a class of deaf and hard of hearing individuals in a disability discrimination action challenging inconsistent, unreliable, and increasingly scrutinized access to sign language interpreting services, co-counseling with the civil rights association the National Association of the Deaf.

Heather has also served as a mentor with an organization serving immigrant, refugee, and asylee lawyers and other professionals seeking employment in the Bay Area. She has also represented plaintiffs in pro bono litigation to secure rights for low-wage workers’ and for disabled youth.

NOTEWORTHY

Named a Northern California Super Lawyer in 2020, and a Rising Star in 2017, 2018 and 2019, as a top-rated antitrust litigation attorney by Super Lawyers, a list issued by Thomson Reuters.

Received Honorable Mention in 2013 from the American Antitrust Institute (AAI) for “outstanding antitrust litigation achievement in private law practice” along with the other members of the Zelle litigation team for work in In re TFT-LCD Antitrust Litigation at AAI’s first annual Antitrust Enforcement Awards.

Bryan Wang Associate

Bryan’s practice focuses on complex litigation, primarily in antitrust law. In this area, he is experienced in collusion, price-fixing, and monopoly matters.

Prior to Zelle LLP, Bryan served as a judicial extern for the Honorable Ernest Hiroshige of the Superior Court, Los Angeles. As an extern, he researched issues for bench memorandums, ranging from anti-SLAPP motions to summary judgments.

During law school, Bryan was a UC Hastings Moot Court Team member. In his final year, he provided instruction as a First Year Teaching Fellow in torts and 555 12th Street as a Constitutional Law teaching assistant. He also helped examine online Suite 1230 mugshot privacy issues as a research assistant Oakland, CA 94607 TEL: (415) 633-1919 ARTICLES & PRESENTATIONS FAX: (415) 693-0770 [email protected] California State Antitrust & Unfair Competition Law (Matthew Bender 2019), PRACTICE AREAS Contributor

Antitrust and Unfair “Alabama Federal Court Allows Antitrust Claims Against Blue Cross Blue Competition Shield for Territorial Allocation, Price-Fixing and Boycott Violations to Proceed Class Actions to Trial,” California Lawyers Association, May 17, 2018, author Corporate Plaintiff Affirmative Recovery eDiscovery PROFESSIONAL AFFILIATIONS Indirect and Direct Purchaser Class Actions American Bar Association

BAR AND COURT ADMISSIONS California Bar Association

State Court: California Asian American Bar Association of the Greater Bay Area

EDUCATION PRO BONO ACTIVITIES University of California, Hastings College of the Law, Bryan graduated as a UC Hastings pro bono society member. He volunteered J.D., cum laude, 2017 monthly in the Legal Advice and Referral Clinic through the Bar Association of University of California, Los Angeles, B.A., 2010 San Francisco offered at UC Hastings.

NOTEWORTHY

At UC Hastings, Bryan received CALI awards for top marks in Antitrust, Prosecuting International Cartels, Compliance: Business & Human Rights, Compliance: Data Privacy, Copyright, and Law Practice Management.

James S. Dugan Associate

James is an attorney in Zelle’s Oakland office. His practice focuses on complex litigation, primarily in the antitrust field. James joined Zelle after working as a summer associate for the firm during law school.

While in law school, James was a co-leader of a student-initiated legal services project. James also spent time during his third year of school working as a law clerk for Root and Rebound, a reentry legal resource center based in Oakland, California.

ARTICLES & PRESENTATIONS 555 12th Street Suite 1230 "Indirect Purchaser Antitrust Standing Heads In New Direction," Competition Oakland, CA 94607 Law360, July 2, 2020, co-author TEL: (415) 633-1913 FAX: (415) 693-0770 “Who’s in Your Class? 2019 Hot Issues in Antitrust Class Action Litigation: [email protected] Ascertainability and Uninjured Class Members”, ABA Section of Antitrust Law PRACTICE AREAS Annual Spring Meeting, Washington, DC, March 26-29, 2019, co-author

Antitrust and Unfair Competition PROFESSIONAL AFFILIATIONS Antitrust Counseling & American Bar Association Compliance Class Actions National Lawyers Guild—S.F. Bay Area Chapter Indirect and Direct Purchaser Class Actions Securities/Securities Lending

BAR AND COURT ADMISSIONS

State Court: California

EDUCATION

UC Berkeley School of Law, J.D., 2018 University of Nebraska Omaha, B.S., summa cum laude, 2014

Exhibit B In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Zelle LLP Reporting Period: Inception through February 28, 2021

Historical Total Hourly Name Status Hours Rate Total Lodestar Micheletti, Christopher P 210.90 $905.00 $190,864.50 Micheletti, Christopher P 15.40 $880.00 $13,552.00 Fu, Qianwei P 12.70 $680.00 $8,636.00 Rankie, Heather A 0.10 $630.00 $63.00 Rankie, Heather A 363.30 $630.00 $228,879.00 Dugan, James A 15.80 $465.00 $7,347.00 Wang, Bryan A 114.40 $475.00 $54,340.00 Wang, Bryan A 16.60 $440.00 $7,304.00 Newman, Robert PL 16.00 $310.00 $4,960.00

TOTALS 765.20 $515,945.50

Partner (P) Of Counsel (OC) Associate (A) Paralegal (PL) Staff/Contract Attorney (CA) Law Clerk (LC) Case 3:18-cv-00850-JAG Document 349-3 Filed 05/03/21 Page 253 of 253 PageID# 11676

Exhibit C In re: Interior Molded Doors Indirect Purchaser Antitrust Litigation

Firm Name: Zelle LLP Reporting Period: Inception through March 31, 2021

Disbursement Amount Electronic Research $1,460.92 Filing / Misc. Fees $1,376.59 Overnight Delivery/Messengers $0.00 Photocopying $0.00 Postage $126.75 Service of Process Fees $0.00 Telephone / Fax $0.00 Transportation / Meals / Lodging $1.35 Litigation Fund Contributions $40,000.00 Expert Fees $0.00 Secretarial OT / Word Processing $0.00 Court Reporter Service/Transcript Fees $0.00 Microfilm / Video / Disks Duplication $0.00 TOTAL $42,965.61 Case 3:18-cv-00850-JAG Document 349-4 Filed 05/03/21 Page 1 of 5 PageID# 11677

Exhibit B Case 3:18-cv-00850-JAG Document 349-4 Filed 05/03/21 Page 2 of 5 PageID# 11678

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

DECLARATION OF WILLIAM V. REISS REGARDING THE LITIGATION FUND IN SUPPORT OF INDIRECT PURCHASER PLAINTFFS’ MOTION FOR AN AWARD OF ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES, AND SERVICE AWARDS TO THE CLASS REPRESENTATIVES

I, William V. Reiss, declare as follows:

1. I am duly licensed attorney in New York and am admitted pro hac vice in this

Court. I am a partner at Robins Kaplan LLP. On December 26, 2018, the Court appointed me as

one of Interim Co-Lead Counsel in the above-captioned action (“Action”), and on February 5,

2021, my firm was appointed Settlement Class Counsel along with Gustafson Gluek PLLC and

The Joseph Saveri Law Firm LLP. My firm is responsible for maintaining and administering the case-specific common Indirect Purchaser Plaintiffs’ (“IPPs”) litigation fund (“Litigation Fund”) in connection with this Action. I have personal knowledge of the matters stated herein and, if called upon, could and would competently testify thereto.

2. I am submitting this Declaration in support of Indirect Purchaser Plaintiffs’

Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the Class Representatives.

3. The Litigation Fund, to which my firm and co-counsel (“IPP Class Counsel”) periodically contributed during the pendency of this Action, was created to cover common litigation costs and expenses.

1 Case 3:18-cv-00850-JAG Document 349-4 Filed 05/03/21 Page 3 of 5 PageID# 11679

4. Attached hereto as Exhibit A is an expense report for the Litigation Fund. From

appointment of Interim Co-Lead Class Counsel on December 26, 2018 through the present,

common litigation costs and expenses incurred in connection with this Action were

$3,224,712.31.1 Of this total, $2,488,377.46 has been paid from the Litigation Fund, while

$736,334.85 in additional common litigation obligations have been invoiced yet remain to be

paid. Total assessments paid by IPP Class Counsel to the Litigation Fund were $2,491,000.2

Accordingly, Settlement Class Counsel seek reimbursement of an additional $733,712.31

($3,224,712.31 - $2,491,000.00). Upon approval of this expense request, Settlement Class

Counsel will pay the additional $736,334.85 in obligations related to the Action.

5. These common litigation expenses were reasonably and necessarily incurred in

connection with the Action.

6. The common litigation expenses incurred are reflected on the books and records

of Robins Kaplan LLP in connection with the Action. These books and records are prepared

from checks, expense vouchers, and other source materials which are regularly kept and

maintained by the firm and accurately represent the expenses incurred.

1 Pursuant to Paragraph 33 of the Settlement Agreement (ECF No. 226-1), Settlement Class Counsel have also paid Poslethwaite & Netterville, APAC, the Court-appointed Notice Administrator and Settlement Administrator (ECF No. 341), $71,367 from the Escrow Account for “costs of providing notice to the Settlement Class and the costs of administration of the Settlement Fund.” 2 Each firm’s individual contribution to the Litigation Fund is included in Ex. A to the Joint Declaration of William V. Reiss, Daniel C. Hedlund, and Steven N. Williams in Support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and Service Awards to the Class Representatives.

2 Case 3:18-cv-00850-JAG Document 349-4 Filed 05/03/21 Page 4 of 5 PageID# 11680

I declare under penalty of perjury under the laws of the United States that the foregoing is

true and correct.

Executed this 3rd day of May, 2021, in New York, New York.

/s/ William V. Reiss William V. Reiss Robins Kaplan LLP

3 Case 3:18-cv-00850-JAG Document 349-4 Filed 05/03/21 Page 5 of 5 PageID# 11681

Exhibit A In re Interior Molded Doors Antitrust Litigation Litigation Fund

Paid Expenses Amount Expert Professional and Consulting Services $2,379,626.25 Document Collection, Processing, and Review, and $78,491.44 Repository Management Third Party Subpoenas $21,111.37 Deposition Transcript, Video and Other Related Costs $8,839.85 Hearing Transcripts $308.55 Subtotal $2,488,377.46

Outstanding Expenses Amount Expert Professional and Consulting Services $682,177.43 Document Collection, Processing, and Review, and $5,882.41 Repository Management Deposition Transcript, Video and Other Related Costs $48,275.01 Subtotal $736,334.85

Total Expenses $3,224,712.31 Assessments paid by IPP Class Counsel to Litigation Fund -$2,491,000.000 Total Unreimbursed Expenses $733,712.31

Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 1 of 15 PageID# 11682

Exhibit C Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 2 of 15 PageID# 11683

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

IN RE: INTERIOR MOLDED DOORS Lead Civil Action No. 3:18-cv-00850-JAG INDIRECT PURCHASER ANTITRUST LITIGATION

Exhibit C

Unpublished Orders and Opinions Cited in the Memorandum in Support of Indirect Purchaser Plaintiffs’ Motion for an Award of Attorneys’ Fees, Reimbursement of Expenses, and for Class Representative Service Awards

Exhibit C-1 In re Polyester Staple Antitrust Litig., No. 3:03-cv-1516, ECF No. 45 (W.D.N.C. June 24, 2008 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 3 of 15 PageID# 11684

Exhibit C-1 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 4 of 15 PageID# 11685

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 1 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 5 of 15 PageID# 11686

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 2 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 6 of 15 PageID# 11687

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 3 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 7 of 15 PageID# 11688

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 4 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 8 of 15 PageID# 11689

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 5 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 9 of 15 PageID# 11690

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 6 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 10 of 15 PageID# 11691

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 7 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 11 of 15 PageID# 11692

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 8 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 12 of 15 PageID# 11693

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 9 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 13 of 15 PageID# 11694

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 10 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 14 of 15 PageID# 11695

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 11 of 12 Case 3:18-cv-00850-JAG Document 349-5 Filed 05/03/21 Page 15 of 15 PageID# 11696

Case 3:02-cv-00474-RLV Document 45 Filed 06/24/08 Page 12 of 12